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Extending short term business visitors relief to overseas branches

Rhiannon Kinghall Were and Nigel Doran (Macfarlanes) review the consultation proposals which are intended to reduce administrative burdens.

HMRC is consulting on extending the relief for STBVs. What is the relief and why is it needed?

The relief for STBVs is needed in countries (‘host states’) such as the UK which tax non-residents on their earnings from any employment duties performed for their foreign employers in the host state even for just a day. Taxing such short visits is inappropriate because:

  • the compliance burden for the employees and the host state tax authority would be wholly disproportionate to the tax collected (often covered by personal allowances);
  • the foreign employer will not normally have a permanent establishment (PE) in the host state so the host state would be taxing the employee but giving...

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