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Non-resident tax

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26 May 2015
Issue: 4502 / Categories: Forum & Feedback , Capital Gains , International , Residence & domicile

Paying a dividend and crystallising capital gains while non-UK resident

I act on behalf of a UK domiciled client who was non-UK resident for five out of seven years to 5 April 2014 and then became non-resident again from that date. He expects to be non-resident until 5 April 2017.

During the two years that he was resident in the UK (2012/13 and 2013/14) he ran a successful company which ceased trading when he became non-resident in April 2014. The company has reserves that are available to distribute.

He also has a personal investment portfolio with some gains that can be realised at any time.

Can we use the current years of non-residence to pay a dividend from the company to the client who is the only shareholder. Could we also realise the capital gains on his investment portfolio with no further UK tax liability?

Query 18 584 – Ex-Pat

Reply from Cello Boy

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