I hope someone can help with this, I am getting rather confused.
A client left the Uk to work overseas and under Case 1 of the SRT will be spliting 2015/16 tax year on 1/7/2015. He is working is Switzerland.
At the end of September 2015 a £100k UK dividend was paid to the client, which grossed up is £111,111 - so there is a liability at 32.5% . I believe that as a Uk dividend it should be declared on the TR, no limit of liability for non residents is available in a split year. The treaty with Switzerland restricts the UK liability to 15%, so I understood that I would claim on HS304 that the UK tax is restricted to £111,111 @ 15% = £16,667.
However HS304 claim form suggests that the £11,111 is excluded from the tax return.
Having read INTM343520 concerning UK dividends it appears to be saying that because 10% tax credit is less than 15% there is no further tax to pay?
So I am not sure if I should exclude the dividend income from the TR, as per HS304, and assume HMRC will eventually issue some sort of assessment for the 15% tax (or maybe INTM343520 does mean no tax due). OR
On HS304 show the total Dividend tax calculated in column D and then the partial relief box (box 22) will reduce the dividend tax to 15%.
One issue with most guidance I have read it is aimed at non residents for a complete year, so because of the limiting rule generally it states there will be no UK tax on the dividends...... wish the dividend was paid the dividend AFTER 6/4/2016 when non resident; a bit easier.
I hope someone can help. Thanks.