Double Trouble – Dual Contracts of Employment

Hundreds of individuals are known by HMRC to have dual contract arrangements. Most of these people are now under HMRC enquiry or will be shortly. Do you fall into this category?

Dual contracts is an area of particular comcern for HMRC since the Chancellor’s negative comments and the introduction of new, anti tax-avoidance rules on 6 April, 2014.

inTAX can advise on how to react to and restructure your current arrangements so as to mitigate the impact of the new rules.

If you think you might need to report a dual contract of employment, or are under scrutiny by HMRC about this issue, speak to one of our experts now.

What are Dual Contracts of Employment?

A dual contract is an arrangement where an employee has two employment contracts with different employers (usually in the same group), covering the whole of their working time.

Dual contracts don’t just apply to straightforward employments. The rules can also affect situations where, for example, there is a combination of UK and offshore employments and or memberships of limited partnerships or limited liability partnerships exist.

Employees who are resident in the UK are subject to UK income tax on their worldwide income. However, if they are non-UK domiciled they are not subject to UK tax on income for wholly non-UK duties with a non-UK employer unless that income is remitted to the UK.

From 6 April 2014, additional conditions must be met to qualify for the remittance basis.

HMRC’s specialist team is now leading tax investigations into all known cases of dual contracts, using the self assessment powers available to it, as well as various international information exchange agreements, the number of which is ever increasing.

Dual Contracts of Employment – how we can help

It is thought that many people haven’t reported that they have a dual contract of employment in place and this in itself means there is a need for specific and careful management of any tax investigations that are started, or, if there is a need to make a voluntary disclosure.

inTAX has good working relationships with the HMRC team that leads tax investigations into dual contracts, and we can provide the requisite specialist technical and practical knowledge to enable the resolution of an enquiry in a suitable time scale.

We will also give proper consideration also to double-taxation treaties when considering the overall strategy for dealing with any given HMRC dual contract tax enquiry.

We provide a focused, goal-orientated and efficient approach to dealing with a HMRC dual contract enquiry. No jargon, no waffle.

For a professional, fuss-free solution to any tax problem, large or small…
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