ARCHIVED: This Practice Note has been archived and is not maintained. It examines the evolution of the tax treatment of dual contract arrangements, including HMRC’s evolving approach and how Finance Act 2014 essentially ended the regular use of these arrangements.
This Practice Note summarises the main UK tax issues that arise in different cross-border employment scenarios, namely when non-UK entities employ UK-based individuals, when UK entities employ non-UK individuals in the UK and when UK entities’ UK employees operate outside the UK. The tax implications of secondments and short-term business visitors (STBVs) to the UK are also detailed, and the issue of tax equalisation agreements is briefly considered. This Practice Note was produced in partnership with Darren Oswick of Simmons & Simmons LLP.
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