Double Taxation Agreement: income from employment in North Sea
In T Kljun v HMRC (TC01226 – 12 July) a Croatian (K) was employed on vessels in the North Sea which were operated by a company resident in the UK.
Tax was deducted from his remuneration under PAYE.
He claimed a repayment contending that he qualified for relief under the UK/Yugoslav Double Taxation Treaty.
HMRC rejected his claim and the First-tier Tribunal dismissed his appeal.
Judge Scott observed that K’s employment ‘was exercised in the United Kingdom’ and was not taxed in Croatia.
She held that double taxation relief was not available ‘where a UK-based company which has the benefit of the employee’s services has borne the costs of remuneration’.
Why it matters: The Tribunal upheld HMRC’s view that double taxation relief was not available where...
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Double Taxation Agreement: income from employment in North Sea
In T Kljun v HMRC (TC01226 – 12 July) a Croatian (K) was employed on vessels in the North Sea which were operated by a company resident in the UK.
Tax was deducted from his remuneration under PAYE.
He claimed a repayment contending that he qualified for relief under the UK/Yugoslav Double Taxation Treaty.
HMRC rejected his claim and the First-tier Tribunal dismissed his appeal.
Judge Scott observed that K’s employment ‘was exercised in the United Kingdom’ and was not taxed in Croatia.
She held that double taxation relief was not available ‘where a UK-based company which has the benefit of the employee’s services has borne the costs of remuneration’.
Why it matters: The Tribunal upheld HMRC’s view that double taxation relief was not available where...
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:
