Employer Of Record employment in Austria working for UK company

Hello, I currently work for a UK-based company and am planning on moving to Austria in the forthcoming calendar year. I intend to continue working for my UK employer via an Employer of Record ('EoR') arrangement wherein I will legally be employed by an Austrian-based entity which will then invoice my current employer for my services. Technically speaking, I will therefore have an employment contract with an Austrian employer (EoR entity). The EoR will then have a Master Services Agreement with my current UK-based employer. My intentions are to work from Austria 75% of the year and the UK for 25% of the year. To this end, I have been researching the UK/Austria Double Taxation Agreement (‘DTA’) as it explains who is considered a Tax resident in Article 4 of the document. It specifies that "in the case that an individual is a resident of both Contracting States, the DTA gives additional guidelines for determining tax residency", namely, if they have a permanent home in both States, "an individual will be considered a resident only of the State with which his personal and economic relations are closer - criterion of centre of vital interest". I believe I satisfy this criteria as I will have an Austrian residency and work visa, my employer will be an Austrian entity and my spouse/family is an Austrian national currently working for an Austrian employer. However, I would like to check with the HMRC as to whether this deduction on my being only Austrian tax resident is valid – and whether the UK/Austria Double Taxation Agreement supersedes the RDR3 Statutory Residence Test. Article 14 of the UK/Austria DTA regulates income from employment. To clarify, my situation will be; - I will reside in Austria for more than 183 days in any 12-month period commencing or ending in the fiscal year; - My salary is to be paid by an employer who is Austrian resident; - My salary will be borne by my employer’s permanent establishment in Austria. Can I please therefore also confirm whether the income I derive whilst living and working in the UK for 25% of the year will be liable for taxation from HMRC? Any assistance would be greatly appreciated. Many thanks.

Hello, I'd value any feedback from HMRC on the above. Many thanks.

Hi

We can only provide general information /guidance in this forum.  
For an answer to a detailed question of this nature, you would need to contact our self assesment helpline on 0300 200 3310, contact our webchat facility at Contact HMRC or seek professional advice.

Thank you