Source of income (and private client)
Source of income (and private client)

The following Private Client practice note provides comprehensive and up to date legal information covering:

  • Source of income (and private client)
  • What is the meaning of source of income?
  • What is the relevance of source for UK income tax?
  • Rental income from land
  • Dividends and other distributions from a UK resident company
  • Dividends from a non-resident company
  • Interest
  • Profits of a trade carried on by a non-resident trading in/with the UK
  • Income from a fixed interest trust governed by English law (and the law of most offshore jurisdictions)
  • Income from a fixed interest trust governed by New York law (and Scottish trusts)
  • More...

Source of income (and private client)

When advising an individual on cross-border or offshore tax planning, it is important to establish the 'source' of income received by or for the individual. This Practice Note explains the relevance of ‘source’ for income tax and looks at the meaning of 'source' for this purpose.

The charge to income tax only arises upon specific types of income pursuant to specific charging provisions within the income tax acts. When considering source, reference must be made to each specific type of income. The Charges to income tax—tables provides an overview of the charges to income tax in each of the categories and the legislative provisions that are relevant to that charge.

What is the meaning of source of income?

The term 'source of income' describes where income arises or where it is derived from. Income arising in the UK has a UK source and income arising outside the UK has a non-UK source (or foreign source).

The situs or location of the asset producing the income is not always the source of such income. For example, the source of dividends is where the paying company is resident and not where the shares are registered (for the situs of shares, see Practice Notes: Situs of assets for succession and IHT and Situs of assets for CGT.

What is the relevance of source for UK income tax?

There is

Related documents:

Popular documents