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TAXguide 07/20: Off-payroll working: cross border issues

A series of questions posed by the ICAEW Tax Faculty exploring the impact of changes to the off-payroll working regime where one of the parties is based outside the UK. Answers have been taken from HMRC's guidance.

TAXguide 07/20

Tax Faculty members can download this guidance in full.

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This guide comprises questions put to HMRC in December 2019, exploring the impact of changes to the off-payroll working regime for medium and large businesses, in particular related to cross border issues.

Pending a direct response from HMRC, ICAEW's Tax Faculty has inserted extracts from HMRC guidance. Therefore, this guidance is based on current understanding of the prospective measures and should be treated as provisional. 

The guide, which has been written by Tax Faculty Volunteer and EY Associate Partner Steve Wade, is split into two sections. The first outlines six scenarios where one of the parties is based outside of the UK, and the second poses a question relating to the interpretation of tax treaties.