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Over-taxed over here?

19 January 2006
Issue: 4041 / Categories: Forum & Feedback

I have a new client who is a United States national and who is working for a United States company here in the United Kingdom. He works out of his home office.
My questions are as follows.

1. Under what circumstances would the US company have a UK tax presence and what are the implications of this?
2. How is the tax paid on his UK earnings since he has a non-UK resident employer?
3. Are there any tax planning issues that can be considered?

I have a new client who is a United States national and who is working for a United States company here in the United Kingdom. He works out of his home office.
My questions are as follows.

1. Under what circumstances would the US company have a UK tax presence and what are the implications of this?
2. How is the tax paid on his UK earnings since he has a non-UK resident employer?
3. Are there any tax planning issues that can be considered?

Any advice from readers on these or any related relevant taxation points that I should be aware of would be appreciated.
Query T16 741 — Uncle Sam.


Reply by Auntie Doris:

First it is well established that the actions of an employee can create a taxable presence in the UK for a non-resident company. This is usually circumvented by an applicable double taxation agreement in the...

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