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Double Trouble

Jennifer Knowlson and Richard Clarke of PricewaterhouseCoopers examine how HMRC enquires into dual-contract arrangements and identify the key technical and factual battle grounds
Dual employment contracts have been a popular way for non- UK-domiciled individuals to exclude from the UK tax net income from an employment the duties of which are performed wholly abroad. Unsurprisingly they are not quite so popular with HMRC. In many cases both employers and employees find themselves subject to a thorough and rigorous investigation where apparently trivial aspects of day-to-day employment are scrutinised in unexpectedly great detail. Dual contracts can sometimes fall at this hurdle since what may seem like an 'incidental' duty to the employee may be seen as substantive by HMRC — the significance of what constitutes incidental duties has long been...

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