RG5.7 - Liability to UK tax: Scope of liability to income tax on investment income

StatusInvestment incomeUK Government securities 'FOTRA' (See RE1731 and AP App.4)
Arising in the UKArising outside the UK
Resident and ordinarily resident, domiciledLiableliableLiable
Resident and ordinarily resident, not domiciledLiableLiable if received in the UK 1Liable
Resident but not ordinarily resident, domiciledLiableLiable 2Not liable 5
Resident but not ordinarily resident, not domiciledLiableLiable if received in the UK 1Not liable 5
Not resident but ordinarily resident, domiciledLiable 3, 4Not liableLiable
Not resident but ordinarily resident, not domiciledLiable 3, 4Not liableLiable
Not resident and not ordinarily resident, domiciledLiable 3, 4Not liableNot liable 5
Not resident and not ordinarily resident, not domiciled.Liable 3, 4Not liableNot liable 5
  1. Income arising in the Republic of Ireland is liable on the arising basis. See DT9856.
  2. Commonwealth (this includes British) or Irish citizens are liable on the remittance basis, other than income arising in the Irish Republic when note 1 applies.
  3. See Appendix 2 and the DT manual about possible relief under a DTA.
  4. The charge to tax may be limited by the operation of ESC B13 up to 5 April 1996 and thereafter, by Section 128 FA 1995 (see AP2188 - AP2189).
  5. Up to 5 April 1998 only certain securities were FOTRA Securities. From 6 April 1998 all securities are FOTRA Securities.

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