My client, a British citizen, has lived in France for many years. Only income sources are UK private and state pension and has not paid tax on this income whilst resident in France under DTA.
They permanently returned to UK during 2019/20, treated as a UK resident but satisfied Split Year Treatment applies. The overseas part of the year is 06/04/2019 - 12/10/2019 and UK for the remainder, though they paid tax in France up to 02/11/2019 as that was the date they wer no longer classed as resident.
Reporting their income on the SA return:
1) Should the pension income be included from 13/10/2019 and relief claimed via HS304 for the overseas part? This would lead to double tax for the period 13/10/19 - 02/11/2019 - can a credit be claimed for tax suffered in France?
2) Pension income included from 03/11/2019 and relief claimed via HS304 for the prior part of the year so no double taxation.
Thanks for any comments.