(1). State the circumstances in which an individual may be regarded as a temporary non-UK tax resident for the purposes of CGT.
(2). Eider had always been tax resident and domiciled in the UK until she moved to the country of Twitcheria for a three-year period on 1 May 2023 at which point she ceased to be UK tax resident. In 2025 Eider will sell two buildings situated in Twitcheria.
Property 1 was acquired in August 2018.
Property 2 was acquired in July 2024.
Explain the UK CGT implications of the disposal of the two properties.
(3). Sparrow was born in the country of Twitcheria. He has acquired a UK domicile and has been UK tax resident for 25 years. Sparrow intends to leave the UK on 1 July 2022 and to move to the country of Kiwiana. He will cease to be UK tax resident and UK domiciled from the date of his departure.
What matters need to be considered in order to determine Sparrow’s deemed domicile status, for the purposes of UK income tax and CGT, following his move to Kiwiana?