Section 17 | Effect of becoming or ceasing to be a UK resident

(1)This section applies if—

(a)an individual carries on a trade (alone or in partnership), and

(b)there is a change of residence.

(1A)For the purposes of this section there is a “change of residence” if—

(a)the individual becomes or ceases to be UK resident, or

(b)a tax year is, as respects the individual, a split year.

(1B)The change of residence occurs—

(a)in a case falling within subsection (1A)(a), at the start of the tax year for which the individual becomes or ceases to be UK resident, and

(b)in a case falling within subsection (1A)(b), at the start of whichever of the UK part or the overseas part of the tax year is the later part.

(2)If this section applies and the individual does not actually cease permanently to carry on the trade immediately before the change of residence occurs, the individual is treated for income tax purposes—

(a)as permanently ceasing to carry on the trade at the time of the change of residence, and

(b)so far as the individual continues to carry on the trade, as starting to carry on a new trade immediately afterwards.

(3)But subsection (2) does not prevent a loss made before the change of residence from being deducted under section 83 of ITA 2007 from profits arising after the change.

(4)This section applies to professions and vocations as it applies to trades.

(5)Repealed