Aussie apportionment

My client was Irish born but she was then resident in Australia for many years until she finally became resident in the UK in May 2002.

Until 2009/10 her foreign income was taxed in the UK on a remittance basis (with little actually remitted) but in 2009/10 having lived in UK for seven out of nine years she became subject to the new remittance regime.

From 2004/05 to date she let her Australian property-making losses for each year until 2009/10.

In 2009/10 she made a profit (which was taxed in Australia despite historic losses) but this was reduced to nil for UK tax purposes by brought-forward losses.

Also in 2009/10 she had Australian interest and dividends of £8 916 with Australian tax deducted of £891.

Her net rental income was £1...