Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Readers’ forum: Rabbit in headlights

04 February 2020
Categories: Forum & Feedback
UK-based earnings for non-resident.

Our client is employed at a high salary by the UK permanent establishment of a business with international operations. All wages with no deductions are taxed under UK PAYE and the full amount is paid into a UK bank account. The client is not a statutory director but has a commanding role in the company such that any of the duties wherever performed around the globe would not be incidental.

Our understanding of the statutory residence test is that the client has two UK ties and would be non-UK resident. Based on working day counts HMRC’s manual at RDRM11150 defines this as 110 in his first year here. We think he may be resident in Belgium. The double tax agreement article 15 indicates that the other state only taxes income from an employment exercised in that state....

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon