Split year treatment meaning

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This Practice Note deals with the application of the residence rules to people leaving the UK after 5 April 2013. The UK introduced its first codified individual tax residence test—the statutory residence test (SRT)—with effect from 6 April 2013. For detailed guidance on the SRT, refer to the Residence after 5 April 2013 Practice Note. Prior to that date, an individual’s UK tax residence was assessed by reference to a patchwork of narrow statutory provisions, case law, established practice and HMRC guidance. Status for any period before 6 April 2013 must therefore still be established under those earlier rules. Application of the SRT looks in part at whether a person was UK resident in the preceding three tax years, meaning residence outcomes for 2010/11, 2011/12 and/or 2012/13 matter when assessing residence from 6 April 2013. Although the pre‑2013/14 years remain governed by the old law, an individual may choose to have their residence in one or more of those years determined under the SRT, solely for the purpose of...

If a company undertakes a share buyback itself, or via an intermediary acting as the company’s agent, the usual tax position for a UK-resident shareholder is that the transaction is regarded, for UK tax purposes at the time of repurchase, as both: a disposal of their shares for chargeable gains purposes, and the receipt of an income distribution Beyond that, the precise treatment differs slightly according to whether the shareholder is an individual or a corporate owner. For further detail on these differences, see Practice Notes: Tax consequences of share buybacks—main rules and Tax consequences of share buybacks—calculating the income capital split. However, special provisions can apply to repurchases by certain unquoted companies. These rules can prevent any of the consideration from being treated as a distribution in the hands of a particular UK-resident shareholder. Under those provisions, the whole sum received by that shareholder is treated as disposal proceeds for CGT/corporation tax on chargeable gains purposes. The comparative advantages of this—ie...

ARCHIVED: This Practice Note is archived and not maintained. Temporary non-residence conditions The pre-2013 regime applies where an individual’s temporary spell of non-residence lasts five years or fewer. As a result, those provisions ultimately lapse on 6 April 2018, when anyone who departed the UK in 2012/13 will have finished a five-year period of non-residence. Paragraph 158 of Schedule 45 to the Finance Act 2013 (FA 2013) provides that the existing temporary non-resident provisions, as they stood immediately before the day the Act was passed, continue to apply on and after that date in any case where the year of departure (as defined in Part 4 of the Schedule) is a tax year prior to 2013–14. The pre-6 April 2013 temporary non-residence conditions are: the taxpayer meets the residence requirements for any year of assessment they did not meet those requirements for one or more years of assessment before the year of return, but there are years of assessment before that year...