Non UK domicile and 5 years of non residence

In order to prevent non UK domiciliaries from simply claiming the remittance basis and then becoming non UK resident and remitting the income free of tax new anti avoidance rules have been introduced. They apply the CGT 5 year non residence requirement so that if you become non UK resident and remit income or gains whilst non resident, those income or gains will be treated as remitted in the tax year of your return - unless you remain abroad for at least five complete tax years. One point that isn't clear yet is whether they will apply the split year basis to this. If you claim the split year basis in the tax year of your departure your overseas income after you leave is exempt from income tax. Therefore whenever it's remitted it should be free of UK tax. However the finance bill states that any income of the year of departure would be subject to the five year non residence period. As the split year basis is a Revenue concession we'll need to wait and see whether it is extended to this non dom scenario.