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The UK has double taxation agreements with more than 100 countries, most of which include a personal services article that will (subject to certain conditions) exempt from UK income tax the income of an employee or self-employed individual who is working on a purely temporary basis in the UK provided that the individual is resident for tax purposes in the other treaty country. In the case of employment income, the relevant OECD 1992 Model Tax Treaty Article is Article 15, but income derived from professional services or other activities of an independent character is dealt with under Article 7 as business profits. Article 7 provides an exemption for business profits arising in the UK where there is no permanent establishment in the UK and the business is resident in the other treaty country. However, this treaty exemption is normally disapplied in most of the UK's tax treaties in the case of entertainers and sportspeople¹.

This disapplication of the normal tax treaty exemption for self-employed individuals in older tax treaties usually takes the form of a wording such