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Posted Tue, 27 Feb 2024 14:36:58 GMT by Finlay R
I have recently come across a person in a somewhat unique situation and I want to understand how their problem would be resolved. A UK self employed person was hired by a US company to accompany a band on a tour around the world (as security). How should they declare this income on a tax return. Is it foreign income? Is it subject to tax within individual countries they worked in? Or is it just income they made as self employed that they owe tax on?
Posted Tue, 27 Feb 2024 15:22:27 GMT by HMRC Admin 17

Hi ,
Their UK residence position would need to be determined. 

If they are tax resident in the UK for the whole tax year, then they would need to declare the foreign income in a tax return. 

If they are not UK tax resident for the whole tax year, then this foreing self employment income is not taxable in the UK . 

The person would need to review the guidance at RDR3 ( and undertake the satutory residence tests, to determine their tax residence status and whether split year treatment would apply .

Thank you .
Posted Tue, 27 Feb 2024 15:35:16 GMT by Finlay R
Their residence all year round is the UK apart from when they are working abroad, as trying it hotels with the band. Typically 3-4 months at a time (of the year) but there is no permanent residence elsewhere. Suppose that means they declare it foreign income. Specifically self employed foreign income which if I'm not mistaken is filing a SA106 with their tax return?
Posted Wed, 28 Feb 2024 11:40:15 GMT by HMRC Admin 25
Hi Finlay R,
The individual will need to review the statutory residence guidance at RDR3 and take the statutory residence tests:
RDR3 Statutory Residence Test
To confirm whether they are considered to be resident in the UK for the whole tax year.
If they are, then then need to look at the guidance on split year treatment, to determine if this applies as well.
If split year treatment applies, then they need to complete form SA109 with their tax return to claim split year treatment.
They do not declare their overseas income in the tax return, other than as a free hand note in the additonal information box.
If split year treatment does not apply, they need to complete SA103 to declare their US earnings and if tax is deducted in the USA, they also need to complete SA106, to declare the tax.
All figures in the tax return are in pounds sterling only.
Thank you. 

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