Genuine Non UK Work for Non UK Domiciled Consultants
If you come to the United Kingdom as a Non-UK Domicile on a temporary work visa using an offshore structure to deal with income arising ‘Outside the UK’ then using an offshore vehicle may be a perfectly legitimate thing to do.
The important thing to remember here is that the income must arise ‘outside the United Kingdom’.
For example an Australian Domiciled Individual arrives in the UK on a Working Holidaymaker Visa. Once they arrive they search for a contract and eventually find one based in France for 2 months.
The Contractor may (depending upon their individual circumstances) work in France for the duration of the assignment and bill the money directly to an offshore structure in the Channel Islands. This income would not attract UK taxes due to the fact that neither the worker nor the work were based in the United Kingdom.
However, if the individual spent long enough in the UK to fall fully within the UK tax net even income arising outside the UK may be taxable by the HMRC.
The individual should also consider the rate of taxation in the respective jurisdiction of the offshore structure. In this example, while the work being done in France means that there may be no UK tax liability, it is probably the case that the French tax authorities will want some tax, but this site does not contain any articles on French tax!
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