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Home / Simons-Taxes /Personal and employment tax /Part E6 Overseas issues /Division E6.1 Residence status /Liability of non-residents / E6.128 Limit on the income tax liability of non-residents—disregarded transaction income
Commentary

E6.128 Limit on the income tax liability of non-residents—disregarded transaction income


Personal and employment tax

The rules limiting the UK income tax liability of a non-resident restrict the amount of tax payable to1:

  1. Ìý

    •ÌýÌýÌýÌý Amount A – the tax deducted at source (if any) from 'disregarded income', plus

  2. Ìý

    •ÌýÌýÌýÌý Amount B – the tax due on all taxable UK source income, excluding disregarded income. The UK income tax is calculated without the benefit of any personal allowances to which the non-resident might otherwise be entitled

See E6.126 for a detailed discussion of the rules.

Disregarded income

There are six categories of disregarded income for the liability of a non-resident as follows2:

  1. Ìý

    (a)ÌýÌýÌýÌý disregarded savings and investment income

  2. Ìý

    (b)ÌýÌýÌýÌý disregarded annual payments

  3. Ìý

    (c)ÌýÌýÌýÌý disregarded pension income

  4. Ìý

    (d)ÌýÌýÌýÌý disregarded social security income

  5. Ìý

    (e)ÌýÌýÌýÌý disregarded transaction income

  6. Ìý

    (f)ÌýÌýÌýÌý any other description of income which the Treasury designate by regulations

It is important to note that any income in relation to which the non-resident has a UK representative

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