ÀÏ˾»úÎçÒ¹¸£Àû

Non-resident entertainers and sportspeople

E5.801 Non-resident entertainers and sportspeople—introduction

Before 1 May 1987 the UK had no special rules to deal with non-resident entertainers and sportspeople performing in the UK although under the UK's domestic legislation the income derived from a UK performance or appearance was taxed either as employment income or as profits from self-employment. At that time, almost all the double taxation agreements entered into by the UK precluded any treaty exemption for the earnings of entertainers and sportspeople, although tax credit relief prevented double taxation (see E5.810). Enforcement of collection of a self-employed non-resident individual's UK tax liability on their UK-sourced income was often extremely difficult, especially where their UK visit was of short duration and this difficulty was exacerbated by the basis of assessment that applied at that time (the individual was assessed in one tax year on their profits for the previous tax year). In addition, the individual might not have profits as an entertainer or sportsperson for the UK tax