Feedback, issue 4063

Game set and match to HMRC

As a US tax lawyer resident in London I have followed with interest Agassi v Robinson [2006] STC 1056 which involved the interpretation of TA 1988 ss 555 and 556 the provisions for taxing the UK activities of non-resident artistes and athletes. Section 555 imposes an obligation to withhold tax on persons making payments for the UK services of non-resident artistes and athletes while s 556 creates a corresponding obligation of the artistes and athletes to pay such tax. The Foreign Entertainers Unit of HMRC was created to enforce this legislation. Non-resident artistes and athletes visiting the UK to perform in an event typically submit a statement of their deductible costs to the FEU ahead of the event permitting it to calculate their liability under s 556 and adjust s 555 withholding to the level needed to meet...