Readers’ forum: Double tax treaty

Double tax treaty

My client works for a company in Saudi Arabia and last year was non-resident in the UK.

For 2020-21 he has been in the UK for 292 days because his father had died Covid restrictions and his back surgery. After taking off 60 days for exceptional circumstances he has a day count of 232 which makes him UK resident under the statutory residence test.

As a UK resident I believe he will be subject to UK tax on the whole of his Saudi Arabia salary which is £1.6m. I believe he is only able to reduce the days according to actual workdays in each country if he is non-UK resident.

However if he is considered resident in both the UK and Saudi Arabia we will be able to turn to the UK/Saudi Arabia double tax treaty to decide...