I'm non-UK national who used to contract for the past 5 years in the UK via a limited company. During this time I accumulated money in my company's. I moved out of the UK in May to Malta.
I went in through SRT test with a tax residency professional who confirmed that I'm non-resident in the UK for the current year. He also said that if I close the company my income tax will be due in Malta because I was a resident of Malta at the time of distribution. With one exception that, if I move back to the UK within 5 years I might still have pay tax in the UK. Following that advice I closed company and distributed the money as dividends as Entrepreneurs' Relief would apply only if I were resident in the UK anyway.
On the other hand, my accountant who usually assists me stated recently that the tax on that dividends will still be due in the UK because the reserves in my company were coming from the work carried in the UK territory. So in his opinion, the fact that I paid it out while being non-resident in the UK doesn't matter.
I know that tax residency is a complex subject so that's why decided to take professional advice on that subject... Unfortunately, I received 2 contradicting answers from 2 professionals so I hoped maybe I will find someone opinion here
Many thanks for any opinion