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A client worked in Norway between 26 April 2011 and 30 June 2012. Local tax was deducted by the Norwegian associated company. The income has been included on the client’s tax return and double tax relief claimed for the tax deducted
We act for a client who worked in Norway between 26 April 2011 and 30 June 2012. The work abroad did not include a complete tax year and our client worked ten days on and four days off while his wife continued to live in the family home in the UK. He was employed by a UK company but seconded to an associated Norwegian company.
The Norwegian company was contracted to carry out work for an end-customer (also Norwegian) and our client’s work on an oil rig was onshore in Norway.
Norwegian tax was deducted by the Norwegian associated company. We have included the income on our client’s tax return and claimed double tax relief for the Norwegian tax deducted.
We are now worried that under the terms of Article 15 of the double tax agreement we should have argued that the remuneration is only taxable...
