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UK INDIVIDUAL TAX
Not Ordinarily Resident

Resident but not Ordinarily Resident
If an individual intends to stay for less than three years and does not buy a home or enter into a long lease, then he or she will usually be resident but not ordinarily resident. This status will continue until the earlier of the beginning of the tax year following the third anniversary of the date of arrival or the beginning of the tax year preceding a change in intention regarding the length of his or her stay.

If an individual is resident but not ordinarily resident (R/NOR), he or she will be taxable on UK source income and gains (including income attributable to UK workdays) as it arises, and on foreign source income only to the extent that the income relating to the foreign source is remitted to the UK. If an individual is R/NOR but not domiciled in the UK, then he or she will also be able to shelter from UK taxation overseas capital gains provided the proceeds are not remitted to the UK. Where an individual is R/NOR and domiciled in the UK, he or she will be taxable on non-UK gains on an arising basis.

The definition of remittance is widely drawn and includes both actual remittances, such as cash transfers to the UK or cash withdrawals in the UK or the use of UK credit cards, and constructive remittances, including repaying capital on an offshore loan or mortgage used to purchase UK property or the use of a non-UK credit card to make purchases in the UK. It can be important to be able to identify the source of funds brought in to the UK since some items will not be taxable (such as capital or the proceeds of an exempt asset) and some will. An individual who is not domiciled in the UK or not ordinarily resident in the UK should therefore consider how best to structure their investments.

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