Artificial use of dual contracts by non-domiciles
This Tax Information and Impact Note explains how the government will tax non-domiciles on the overseas employment income it identifies according to the ‘arising’ basis.
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This measure supports the government’s objective of making the tax system fairer. It targets and prevents contrived arrangements by a small number of high earning UK resident non-domiciled individuals who create what are typically artificial divisions between the duties of a UK employment and an employment overseas in order to obtain a tax advantage.