Michael Ingle of Baker & McKenzie LLP's London Employee Benefits Group considers HMRC's increasingly aggressive approach to the use of dual contract arrangements
Dual contracts of employment (sometimes called split contracts) have been used for many years by non-domiciled individuals working in the UK to reduce their overall UK tax liability. Essentially they involve an individual working under two contracts of employment normally with two employing companies in the same group. One contract (the foreign contract) will relate to duties performed outside the UK while the other contract (the UK contract) will relate to duties performed in the UK though the UK contract need not in fact be limited geographically in this way.
The use of dual contracts is well founded in tax law as will be seen below but...
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Michael Ingle of Baker & McKenzie LLP's London Employee Benefits Group considers HMRC's increasingly aggressive approach to the use of dual contract arrangements
Dual contracts of employment (sometimes called split contracts) have been used for many years by non-domiciled individuals working in the UK to reduce their overall UK tax liability. Essentially they involve an individual working under two contracts of employment normally with two employing companies in the same group. One contract (the foreign contract) will relate to duties performed outside the UK while the other contract (the UK contract) will relate to duties performed in the UK though the UK contract need not in fact be limited geographically in this way.
The use of dual contracts is well founded in tax law as will be seen below but...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
