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Received wisdom
Key points
- Employment income is taxed on UK residents wherever it was earned.
- Non-residents will be taxed on earnings from work performed in the UK.
- The importance of determining when earnings are ‘for’.
- Examples of assessment for resident and non-UK resident taxpayers.
- Although Mr Murphy had to satisfy specific employment conditions over a period of time the earnings were for the year of payment.
- Was the tribunal’s decision correct? An alternative view might have been taken.
It is reasonably well known that the charge to income tax on employment income extends (broadly speaking) to income that is earned anywhere in the world by someone who is a resident of the UK (ITEPA 2003 s 15). Further it encompasses income that is earned in the UK regardless of the residence status of the person earning the income (ITEPA 2003 s 7). If that creates a potential double...
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