Part 2Trading income

Chapter 2Income taxed as trade profits

Starting and ceasing to trade

17Effect of becoming or ceasing to be a UK resident

1

This section applies if—

a

an individual carries on a trade wholly or partly outside the United Kingdom otherwise than in partnership, and

b

the individual becomes or ceases to be UK resident.

2

The individual is treated for income tax purposes—

a

as permanently ceasing to carry on the trade at the time of the change of residence, and

b

so far as the individual continues to carry on the trade, as starting to carry on a new trade immediately afterwards.

3

But subsection (2) does not prevent a loss made before the change of residence from being F1deducted under section 83 of ITA 2007 from profits arising after the change.

4

This section applies to professions and vocations as it applies to trades.

5

In the case of a trade carried on by a firm, see sections 852(6) and (7) and 854(5).