Gill Salmons

Hi there My client left the UK to work on ships in January 2024 and will have a qualifying period for SED purposes assuming he's out until at least January 2025. This is certainly the plan. Can he file a 23/24 tax return in January 2025 to show that he was eligible for the deduction for the last 3 months of the 23/24 tax year or does he have to make a separate claim later? We can't find the answer in the guidance. Many thanks

Hi there My client is resident overseas in a country with which the UK has no double tax treaty. They are approaching retirement age and would like to have their pension paid from a UK company pension scheme of which they have been a member for many years. Their question is, whether there would be UK tax payable on this pension or not. It seems to me that this pension would be taxable in the UK since there is no reason for it not to be. Do you agree? Am I missing anything please?

Thanks but if you are resident but not UK domiciled then you do not necessarily need to report worldwide income. That depends on whether the remittance basis is being claimed. Please can you provide me with some guidance in respect of Article 18 of the UK-HK treaty. Is the income from the Hong Kong health department treated as received from the HK government and where can I find evidence of this please?

I have been approached by a potential client who is on a secondment from Hong Kong for 12 months split over 2 UK tax years. They are likely to be resident in the UK under domestic law but also resident in HK and will probably fall to be treated as treaty resident in HK. I understand that the potential client holds a UK passport as well as a HK passport but has never lived in the UK until now and will return permanently to HK at the end of the 12 month period. Employment income is being received from the HK government, I understand, while the individual is here working as a doctor for the NHS. The individual thinks that the income received will not be taxable in the UK under Art 18 of the UK HK double tax treaty. I'm finding Art 18 pretty impenetrable but it seems to me that it says that the income can be taxed in both jurisdictions since the individual doesn't meet the conditions in subsection (b) and subsection (a) does not apply anyway. The other question is whether the income counts as government service at all and I can't find any guidance on this. I would be grateful for your help. Many thanks