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HMRC internal manual

Double Taxation Relief Manual

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Double Taxation Relief Manual: Guidance by country: United States of America: Regular crews of ships and aircraft

The new Agreement with the USA applies for UK income tax from 6th April 2003 and for US tax from 1st January 2004. It provides that a UK resident whose earnings are from employment as a member of the regular complement of a ship or aircraft operated in international traffic shall be taxable only in the UK on those earnings. Similarly a US resident whose earnings are from employment as a member of the regular complement of a ship or aircraft operated in international traffic shall be taxable only in the USA.

This is a change from the position under the previous treaty, which applied up to those dates. The old treaty allowed the country where the employing enterprise was a resident to tax such earnings as well, to the extent permitted by domestic legislation.