Policy paper

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.



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.

Published 19 March 2014