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Dual contracts


Produced by Tolley in association with
Employment Tax
Guidance

Dual contracts


Produced by Tolley in association with
Employment Tax
Guidance
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Introduction

UK resident individuals who are non-UK domiciled under general law can, up to 2024/25, benefit from the remittance basis of taxation which allows for relief from UK tax for non-UK sources of income which are not brought in (or remitted) to the UK in any way.

Note that the non-UK domicile basis of taxation is abolished from 2025/26 onwards. Full details are set out in the Abolition of the remittance basis from 2025/26 guidance note. Most of the following guidance therefore relates to years up to 2024/25. The potential for planning via the use of dual contracts, already limited as explained below, is therefore greatly reduced from 2025/26 onwards. On a practical basis, the remittance basis rules are however likely to remain relevant after 5 April 2025, but only insofar as a non-UK domicile has overseas income arising up to 5 April 2025, which has not been remitted to the UK by that date.

Up to 5 April 2025, one way in which the remittance basis can be utilised for employees is through the use of dual

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Paul Tew
Paul Tew

Writer and advisor at Paywatch

Paul Tew is a freelance adviser, primarily in the areas of pay, personal taxation and remuneration planning. A frequent contributor to technical journals on pay and benefits issues, having written for the "In Business" section of the Times. Paul continues to supply articles for various recognised professional publications including Pay and Benefits magazine, Taxation magazine and Company's Secretary's Review. Paul also has had several loose leaf and bound books published on a variety of subject matter including PAYE, NIC, Sickness and Maternity Pay.Paul has written and presented training courses as well as headed up payroll and employment help desks and acted as an assessor for recognised Payroll/HR qualifications. Paul previously worked in the healthcare and oil sectors managing Pay and benefit services, so has many years of experience in dealing with PAYE and employment compliance issues across a broad range of industries and organisations.

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