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Ask an expert: Tax on split or dual contracts for overseas executives

There must be two or more distinct roles, says Andrew Roycroft

Question: My client (an international group) is recruiting an executive for a senior role which will be predominantly based in the UK but with responsibility for the EMEA region. The likely candidate is a non-EU citizen who recently resigned from his current position working in Ireland for an unrelated business and has requested that my client consider various proposals to enable him to be taken on ‘tax-efficiently’. These include using a ‘split’ contract of employment. My client is willing to co-operate but is concerned whether this is appropriate here. Is a ‘split’ contract different from a ‘dual’ contract and could it be used in this situation?

Answer: Businesses organise their workforce in a variety...

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