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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: United States of America: Teachers

Old Agreement: applies for UK tax up to 5th April 2003

One of the conditions for the exemption from United Kingdom tax for a period of up to two years of the remuneration of visiting teachers from the United States is that the visit is ‘for the purpose of’ teaching etc. Where an individual from the United States is transferred to the United Kingdom in the course of his or her employment or in the exercise of his or her professional activities and is accompanied by his or her spouse who then takes up employment in the United Kingdom as a teacher, any claim by the spouse to exemption under Article 20(1) should be refused on the grounds that the purpose of his or her visit was to accompany his or her spouse and not to teach (see DT1936 sub-head (a)).

New Agreement: applies from 6th April 2003

Article 20A is identical to the teachers article in the previous treaty and provides a two year tax exemption for UK and US resident professors or teachers who visit the other country for not more than two years for the purpose of teaching or engaging in public interest research at a university, college or other recognised educational institution. The exemption relates only to remuneration derived from such teaching and public interest research.

One of the conditions of receiving the exemption is that the teacher or professor may stay in the other country for only two years. If they stay longer, they will be treated in the same way as any other group of employees, and tax will be payable for the full period, starting from the first day of the visit.