Readers forum: Overseas complication

I am helping one of my large corporate clients deal with the forthcoming introduction of the off-payroll rules for the private sector. My client is looking at each of their contractors on a case-by-case basis and I am satisfied (as far as one can ever be in such a subjective area as this) that the procedures which have been put in place will correctly identify cases where there would be an employment relationship in the absence of the intermediary in the arrangements.

There are a couple of cases where the worker is a foreign national (one from Spain and one from Poland) who is working for part of the year in the UK for my client company by way of a personal service company which is established in their home countries (Spain and Poland respectively). My client believes neither individual is tax...