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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Isle of Man: double taxation agreement, Article 7: Income from personal (including professional) services

(1) An individual who is a resident of the United Kingdom shall be exempt from Manx tax on profits or remuneration in respect of personal (including professional) services performed within the Island in any year of assessment if -

(a) he is present within the Island for a period or periods not exceeding in the aggregate 183 days during that year, and

(b) the services are performed for or on behalf of a person resident in the United Kingdom, and

(c) the profits or remuneration are subject to United Kingdom tax.

(2) An individual who is a resident of the Island shall be exempt from United Kingdom tax on profits or remuneration in respect of personal (including professional) services performed within the United Kingdom in any year of assessment if -

(a) he is present within the United Kingdom for a period or periods not exceeding in the aggregate 183 days during that year, and

(b) the services are performed for on or behalf of a person resident in the Island, and

(c) the profits or remuneration are subject to Manx tax.

(3) The provisions of this paragraph shall not apply to the profits or remuneration of public entertainers such as stage, motion picture or radio artists, musicians and athletes.