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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....

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