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A non-UK resident lives in Singapore, but owns an investment property in the UK and the rental income profit is subject to UK income tax. He also makes donations to UK charities
Our client is non-UK resident and lives in Singapore. However he owns a property in the UK which he rents out and from which he earns sufficient profit to have a UK income tax liability. Our question is whether he is entitled to sign a gift aid declaration with regard to donations that he makes to UK charities.
Before it was repealed FA 1990 s 25(2)(i) confined relief to individuals resident in the UK; however there was an exception where a gift aid payment was made by an individual who was resident in a state with which the UK had a double taxation agreement (DTA).
In such a case if the DTA included a non-discrimination article relief could be given provided that the non-resident individual is carrying on business in the UK through a permanent establishment and the payment was made by that permanent...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
