445. Cases involving actual or deemed arrival in the UK.

The following are the circumstances in which a tax year may be a split year for an individual where the circumstances of the case involve actual or deemed arrival in the United Kingdom1.

The circumstances of a case fall within Case 4 (starting to have a home in the UK only) if they are as described below2, namely:

  1.  

    (1)     the taxpayer was not resident in the UK for the previous tax year3;

  2.  

    (2)     at the start of the relevant year, the taxpayer did not meet the only home test4, but there comes a day in the relevant year when that ceases to be the case and the taxpayer then continues to meet the only home test for the rest of that year;

  3.  

    (3)     for the part of the relevant year before that day, the taxpayer does not have sufficient UK ties5.

The circumstances of a case fall within Case 5 (starting full-time