ordinary residence

In practice, this has an impact for CGT on emigrants
who may still be O/R when they have ceased to be Resident. There are those who believe the distinction is obsolete.

It also has a bearing on a UK domiciled individual who is only resident by chance[ say more than 183 days in the UK, perhaps because of illness.The disregard of extended days in the UK does not apply for the 183 day test, as it applies only for the 90 day test ]and so not O/R, who is taxable on a the same remittance basis as a non dom individual .

Number of Implications
James:
There are quite a number of implications of being/not being UK OR. Three of the most obvious are that:

1. Persons who are not UK OR pay income tax on the remittance basis on overseas investment income (whether domiciled here or not).
2. Persons who are OR are liable to CGT whether resident here or not.
3. Sec 739/740 do not apply if the transferor (739) or beneficiary (740) is not OR.

What is your interest in this?

Harry

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