SALF701 - Self Assessment for Non-Residents: Outline

SALF702 Introduction

SALF703 Taxation of UK property income of non-residents

Purpose of the rules

Circumstances in which the rules apply

ICTA88/S42A(1) and (2)

Right of retention for agents and tenants

ICTA88/S42A(3)

The arrangements are in Regulations made by the board of HMRC

ICTA88/S42A(1) and (4)

The Regulations allow for rent to be paid gross in certain circumstances

ICTA88/S42A(4)

Interest and penalties

ICTA88/S42A(4), (5) and Section 98

SALF704 UK representatives of non-residents chargeable under Case I & II Sch.D

Introduction

The UK representative rules apply to all non-residents

FA95/S126(1)

Definition of UK representatives

FA95/S126 (2) and (8) & FA2003/S150(2)

General rule for the obligations and liabilities of UK representatives

FA95/Sch23/paras 1-3 & FA2003/S150(3)-(4)

Obligations and liabilities are limited where the UK representative is independent of the non- resident

FA95/Sch23/paras 4 and 7 & FA2003/S148(3) and S150(5)

Offences

FA95/Sch23/para 5 & FA2003/S150(6)

UK representatives retain any obligations and liabilities for the period of agency after the period has ended

FA95/S126 (3) & FA2003/S150(2)(c)

UK representative is treated as a separate person

FA95/S126(4)

A partnership can be the UK representative of a non-resident

FA95/S126 (5) & FA2003/S150

Partnership, which includes non-resident partners, trading in the UK through a branch or agency/permanent establishment: the branch or agency/permanent establishment is treated as the UK representative of non-resident partners

FA95/S126 (6) & FA2003/S150(2)

Partnership trading in the UK which includes resident and non-resident members is treated as UK representative of non-resident partners

FA95/S126(7)

SALF705 Agents who are not treated as UK representatives

Introduction

Exempt agents: casual agents, Lloyd’s members’ agents, brokers and investment managers

FA95/S127 (1) & FA2003/Sch26/Para 1

Brokers

FA95/S127(1)(b) and (2)

Investment managers

FA95/S127(1)(c)

Investment managers: the investment transaction condition

FA95/S127 (12) & FA2003/Sch26/Para 3 & SI2003/2172-3

Investment managers: the ‘independent agent’ condition

FA95/S127(3) & FA2003/Sch26/Para 3

Investment managers: the ‘20%’ condition

FA95/S127(3)(d) and (4)-(7) & FA2003/Sch26/Para 4

SALF706 Self Assessment for Non-Residents: Limit to Income Tax Charge on Non-Residents

Introduction

Income tax

FA95/S128 & FA2003/S151

Details of the limit on income tax

FA95/S128 (2) to (6) & FA2003/S151

Example: Non-resident individual - Operation of FA95/S128 limit for income tax

SALF707 Change in residence status

In future changes in residence status will trigger a deemed commencement or cessation for the purposes of assessing business profits

ICTA88/S110A

SALF708 Non-resident partners

Changes in the resident status of a partner trigger a deemed commencement or cessation for the purposes of assessing business profits

ICTA88/S112