Commentary

E1.403 Savings and investment income—territorial scope of charge

Personal and employment tax

E1.403 Savings and investment income—territorial scope of charge

E1.403 Savings and investment income—territorial scope of charge

Subject to any express provision to the contrary in any provision of the Taxes Acts (including ITTOIA 2005, Pt 4 (ss 365–573)):

  1.  

    •     income arising to a UK resident is chargeable under ITTOIA 2005, Pt 4 irrespective of the place of its source

  2.  

    •     income arising to a non-UK resident, or to a UK resident in the overseas part of a split year, is only chargeable under ITTOIA 2005, Pt 4 if its source is in the UK1

Where an amount that is charged to tax as income does not have

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