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Double taxation agreements and employment taxes

Produced by Tolley in association with
Employment Tax
Guidance

Double taxation agreements and employment taxes

Produced by Tolley in association with
Employment Tax
Guidance
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Introduction

In some circumstances, an individual may be liable to tax in two jurisdictions simultaneously where they are employed in one country but spends time working in another. A double tax treaty between countries can be relied upon in many cross-border situations to exempt an income source from taxation in a particular country. However, double tax treaties are not all identical and care should be taken in determining how treaty provisions may apply to individual employees.

This guidance note covers double tax treaties as they apply to employment income, but it does not cover international social security agreements (for which, see the Social security agreements guidance note).

Treaties are generally set out in a standard format with the same article number addressing the same issue in every treaty. In order to ascertain the employment tax position for an individual employed in one country but spending periods working abroad, the ‘residence’ Article and the ‘income from employment’ or ‘dependent services’ Article of the applicable treaty are the most relevant.

For the full text of each

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Gill Salmons
Gill Salmons

Director at Global Eyes Tax Services Limited


I am a member of both the CIOT and ATT and have over 15 years' experience of working with expatriate populations, working inside and outside the Big 4 but mainly in the mid-tier. My clients have included household names as well as much smaller businesses, with expatriate populations as small as 1 or as large as 650+. Each size of business has its own challenges, which is what makes this work interesting; the cultural aspect to working with individuals from around the world cannot be overlooked! I have experience in general employment tax work, including elements of UK and international payroll as well as expatriate tax issues, and have also spent considerable amounts of time dealing with National Insurance matters for inbound and outbound assignees.

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  • 12 Dec 2022 10:40

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