Commentary

E1.415A Dividends etc from UK resident companies—temporary non-residents and close company distributions

Personal and employment tax

E1.415A Dividends etc from UK resident companies—temporary non-residents and close company distributions

E1.415A Dividends etc from UK resident companies—temporary non-residents and close company distributions

Finance Act 2013 introduced extensive anti-avoidance provisions relating to close company distributions and temporary non-UK residence. These affect UK resident companies, non-UK resident companies (see E1.416), stock dividends (see E1.420), release of loans to participators (see D3.401C), income charged under the sweeping-up provisions in ITTOIA 2005, ss 687–689A (Pt 5, Ch 8) (see E1.587) and the limit on liability to income tax for non-UK residents (see E6.126). All are based on the central definition of temporary non-residence in FA 2013, Sch 45, para 110 (see E6.137A).

In relation to

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial