Income Tax (Trading and Other Income) Act 2005 section 832A

Section 832: temporary non-residents

Section 832A deals with the tax treatment of relevant foreign income remitted to the UK by individuals who are temporarily non-resident and taxed on the remittance basis.

  • If an individual who is temporarily non-resident remits relevant foreign income to the UK during their period of non-residence, that income is treated as remitted in the period of return
  • The foreign income caught by this rule is income for the UK part of the year of departure or any earlier tax year, where section 832 (remittance basis) applies to it
  • Any apportionment needed to determine the amount of foreign income relating to the UK part of a split tax year must be carried out on a just and reasonable basis
  • Double taxation relief arrangements cannot prevent the individual from being charged to income tax on foreign income treated as remitted in the period of return

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