Is it possible to disapply the split year basis?

The concept of the split year basis in taxation primarily relates to individuals who may be considered tax residents in more than one jurisdiction during a tax year due to their movements across borders. In the context of UK tax law, the split year treatment allows an individual who becomes resident partway through a tax year (or ceases to be resident partway through) to have their income taxed only on that portion of the year for which they are resident.

To address the idea of disapplying the split year basis, it’s important to clarify that there are indeed specific conditions under which a taxpayer can opt out of this treatment or that it may not apply based on their circumstances. However, stating that it cannot be disapplied entirely overlooks the situations where the taxpayer’s individual circumstances might make the split year treatment not applicable or it can be forfeited by the taxpayer.

For example, if the individual has established their residency status and does not meet the criteria for split year treatment, then they would be fully taxed as a resident for the entire year, thereby effectively disapplying the split year basis. This is more nuanced than simply saying it cannot be disapplied.

Overall, the correct interpretation is that while the split year basis typically applies under certain conditions, there