Middle East muddle

An odd situation has arisen on a new client’s 2014 tax return. The client and his wife worked overseas for a couple of years so were considered to be non-resident in 2012/13. They returned to the UK in April 2013 but the client took up a new permanent job in Abu Dhabi in September 2013.

We have looked at the statutory residence position and find that he can claim split-year treatment for returning to the UK in April. However our understanding is that he will be taxable on all of his earnings from September 2013 to April 2014 because split-year treatment cannot be used for leaving the UK after a short period of residence.

Is our interpretation of the law correct? If so is there anything that could have been or can be done to ameliorate the position?

Query 18 534 – Sheikhen

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