Commentary

E1.1206 Residence matters

Personal and employment tax

E1.1206 Residence matters

E1.1206 Residence matters

The occupation in question must be carried on, wholly or partly, in the UK; there is no requirement for the individual to be resident in the UK1.

HMRC's interpretation of this rule is as follows2:

  1.  

    •     where the occupation is carried on wholly in the UK, the whole of the gain is chargeable, irrespective of the residence of the individual

  2.  

    •     where the occupation is carried out wholly outside the UK, the SIPO provisions do not apply

  3.  

    •     where the occupation is carried out partly in the UK and partly abroad

    1.  

      –     if the individual is resident in

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