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The ocean wave

13 June 2007
Issue: 4112 / Categories: Forum & Feedback

My client left the UK on 11 September 2005 to take up employment in the Virgin Islands as a private yachting captain.
This employment lasted until 10 September 2006 and my client returned to the UK for a short period while negotiating a contract with a new employer based in the Isle of Man. He commenced this employment on 1 October 2006 and is employed on private yachts outside UK waters. He is engaged on lengthy voyages and only spends brief leave visits in the UK which are well under the 91-day average.

My client left the UK on 11 September 2005 to take up employment in the Virgin Islands as a private yachting captain.
This employment lasted until 10 September 2006 and my client returned to the UK for a short period while negotiating a contract with a new employer based in the Isle of Man. He commenced this employment on 1 October 2006 and is employed on private yachts outside UK waters. He is engaged on lengthy voyages and only spends brief leave visits in the UK which are well under the 91-day average.
However my problem is in trying to determine whether he will be classed as non-resident in the UK for tax purposes. He has been employed on overseas yachts for over a complete income tax year (although he did switch employers); he does not sail in UK waters at all and spends less than 91 days in...

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