Introduction

The rules for individual non-residents at FA 1995/S128 and for non-resident companies at FA2003/S151 limit the income tax charge on non-residents. Broadly, they put into law what was previously achieved by extra- statutory concession. The rules are in line with the accepted principles of international taxation in the OECD Model Tax Convention and Double Taxation agreements between the UK and other countries.

Income tax

FA95/S128 & FA2003/S151

In summary, the effect of these rules is that income tax chargeable on non- residents in respect of:

most types of income from investments (except property in the UK, SALF703)

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