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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Effects of residence/domicile: arrivals and departures during a tax year - split year treatment for years from 2013-14

Under the rules within the SRT an individual will be either resident or not resident in the UK for a year of assessment.

However for the year of assessment in which an individual either arrives in or departs from the UK, split year treatment may apply.

There are eight types of occasion, called Cases, that might give rise to split year treatment and each of these Cases have specific rules to determine if split year treatment applies for the year of assessment. The details of which can be found within the Residence Domicile and Remittance Manual.

When split year treatment applies, the year of assessment is split into a UK part and an overseas part. Normally this will mean that the individual is not chargeable to capital gains tax in respect of any chargeable gains accruing to him or her in the overseas part of the year.

This normal rule may not apply where:

  • The individual would have been chargeable to CGT under TCGA1992/S10 (non-UK resident trading through a branch or agency) had the individual been not resident in the UK for the year see CG25515
  • TCGA1992/S10A (temporary non-residence periods) applies see CG26500+
  • Gains attributed under TCGA92/S86 that arise in a year are treated as falling within the UK part of a slit year. See CG38400+.