Confusion in Bermuda

We have a number of non-UK resident clients who live and work in Bermuda most of whom are British nationals. Some undertake work on trips to the UK whether they are visiting purely for business purposes or it is tagged on to their holiday.

Given that there is no double tax agreement between the UK and Bermuda our understanding is that unless the duties of employment performed in the UK are “merely incidental” to their overseas work such duties of employment carried out in the UK will be liable to UK income tax as though incurred here.

Any such work would be taxed under the UK employment income rules as a proportion of their overseas gross salary bonus employee share scheme exercises and employment benefits (such as medical insurance and housing allowance) on a “just and reasonable” basis. We have used the number...