Taxation of international executives
The extent of the liability to UK tax on earnings depends upon the individual’s residence status in the United Kingdom. This is determined using the Statutory Residence Test (SRT).
The domicile status of the individual can also affect the tax liability and this is particularly relevant as many cross border inbound assignees are likely to be foreign domiciliaries (non-doms).
The article that follows is based on the law as it stands at the time of writing (March 2020).
The maximum UK income tax rate for the tax year ending 5 April 2021 is 45 percent (the UK tax year that runs from 6 April 2020 to 5 April 2021 is commonly referred to as 2020/21).
The UK tax authority is known as Her Majesty’s Revenue and Customs (HMRC).
The official currency of the UK is the pound sterling, often referred to just as sterling or as the British pound (GBP). The UK has a decimal currency system with 100p (pence) making up GBP 1 (one pound).
Herein, the host country/jurisdiction refers to the country/jurisdiction to which the employee is assigned. The home country/jurisdiction refers to the country/jurisdiction where the assignee lives when they are not on assignment.
All information contained in this publication is summarized by KPMG LLP, the UK member firm affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity, based on Income and Corporation Taxes Act 1988; Income Tax (Earnings and Pensions) Act 2003; Income Tax (Trading and Other Income) Act 2005; Income Tax Act 2007; Finance Act 2013; Taxation of Chargeable Gains Act 1992; Taxes Management Act 1970; Social Security Contributions and Benefits Act 1992; Social Security (Contributions) Regulations 2001; and Inheritance Tax Act 1984 (all as amended by subsequent legislation); Her Majesty’s Revenue & Customs (“HMRC”) booklets as follows: “Guidance Note: Statutory Residence Test (SRT), RDR3” published December 2013; “Guidance Note: Overseas Workday Relief (OWR), RDR4” published May 2013; immigration rules on the UKVI website at https://www.gov.uk/guidance/immigration-rules and https://www.gov.uk/settled-status-eu-citizens-families
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