My client has always been UK resident, but she left the UK in January 2024 and she will be non-UK resident for 2024-25. She has moved to Canada temporarily and plans to come back in three years’ time.

She is the sole shareholder of a UK company, from which she only takes dividends, and has some UK property income. I understand that as a non-UK resident she is only taxable on UK sourced income, but that dividends are disregarded income. Therefore, is she only taxed on the property income?

Limitation of a non-UK resident’s income tax liability

It seems there might be a common misconception that ‘disregarded income’ is not assessable.

Disregarded income is still assessable income, but for non-UK residents, there is a limitation to their UK income tax liability by virtue of section 811 Income Tax Act 2007 (ITA 2007).