Readers’ forum: Will non-resident pay UK tax on company dividends?

My client is a successful musician who operates via her personal service company (PSC). Over the years she has built up considerable reserves in her company.

In the spring (before 6 April) she is intending to move to mainland Europe for a couple of years to build up her international reputation. Her plans are not completely fixed yet but it is likely that she will spend several months in a number of different countries while she is away rather than base herself in just one. I am happy that she will not be resident in the UK in the two tax years when she is away.

She has asked me whether the company could pay her the accumulated reserves as a dividend in a year of absence without a UK tax charge (she would take local advice on the taxation in the country she is residing in when the...