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What are the rules around UK dividends of a non-UK resident?

Question:

I am thinking of moving to Spain for three to five years and renting out a property whilst out there. I have a consultancy business in the UK (working from home) and any meetings required would be done as virtual meetings. I understand I wouldn't be taxed in Spain or the UK on my UK dividends, which, other than a small salary, is my only income. Are there any temporary non-resident issues I need to be aware of if I come back within five years or transfer back any funds to the UK, and will there be any tax implications?  

Arthur replies: 

I can't comment on whether you will be taxed in Spain on dividends received from the UK. However, you are correct that UK dividends received by a non-UK resident can qualify for 'disregarded income' (see HMRC’s Helpsheet HS300) and be potentially exempt from UK tax. However, see HMRC’s Residence, Domicile and Remittance Basis Manual at RDRM12700, which explains that if a non-UK resident receives UK dividends from a close company in which they are a material participator, and those dividends come from profits earned before they became non-UK resident, and they return within the five-year threshold (i.e., during a period of temporary non-residence), those dividends are subject to UK tax in the year they return to the UK. 

I am thinking of moving to Spain for three to five years and renting out a property whilst out there. I have a consultancy business in the UK (working from home) and any meetings required would be done as virtual meetings. I understand I wouldn&

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This question was first printed in Business Tax Insider in January 2025.