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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: Artistes and athletes

Old Agreement

An artiste or athlete who is a resident of the United States and who exercises his profession in the United Kingdom will not be liable to United Kingdom tax for any year of assessment in which his United Kingdom gross earnings (including any reimbursed expenses) do not exceed US $15,000 or the sterling equivalent (Article 17(1)). If the artiste or athlete is self-employed or receives income through a controlled entity, for example a personal service company, withholding tax may have been paid during the year (see DT1745). Where withholding tax has been deducted no repayment of that tax should be made without reference to the Foreign Entertainers Unit.

New Agreement

The provision is now at Article 16 and is entitled “Entertainers and sportsmen”. The thrust of the article is exactly the same except the monetary limit has been increased to $20,000 (Article16(1)). As before, where withholding tax has been deducted no repayment of that tax should be made without reference to the Foreign Entertainers Unit.