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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Non-residents: UK income: Employment

Refer to Employment Income Technical all claims to the exemption of employment income fromUnited Kingdom tax (DT1920 onwards) where

  • the tax at stake in that case exceeds £50,000, or
  • the company claimed to be the employer is apparently based in a tax haven, or
  • difficulty is experienced in applying the guidance at DT1920 onwards in a particular case.

As the instructions in DT410 explain, a claim to exemption under an agreement is aclaim to the Board by virtue of ICTA88/S788(6) and a notice of decision on a claim may notbe given by an Inspector. If you reach the point where you are unable to reach agreementwith the taxpayer please send the case to Employment Income Technical.