(iii) The extent to which Amy will be subject to income tax in the UK on her earnings in r

Question

(iii) The extent to which Amy will be subject to income tax in the UK on her earnings in respect of duties

performed for Cutlass Inc and the travel costs paid for by that company. (5 marks)

Appropriateness of format and presentation of the report and the effectiveness with which its advice is

communicated. (2 marks)

Note:

You should assume that the income tax rates and allowances for the tax year 2006/07 and the corporation tax

rates and allowances for the financial year 2006 apply throughout this questio

Answer 1

正确答案：
(iii) Amy’s UK income tax position
Amy will remain UK resident and ordinarily resident as she is not leaving the UK permanently or for a complete tax year
under a full time contract of employment. Accordingly, she will continue to be subject to UK tax on her worldwide income
including her earnings in respect of the duties she performs for Cutlass Inc. The earnings from these duties will also be
taxable in Sharpenia as the income arises in that country.
The double tax treaty between the UK and Sharpenia will either exempt the employment income in one of the two
countries or give double tax relief for the tax paid in Sharpenia. The double tax relief will be the lower of the UK tax and
the Sharpenian tax on the income from Cutlass Inc.
Amy will not be subject to UK income tax on the expenses borne by Cutlass Inc in respect of her flights to and from
Sharpenia provided her journeys are wholly and exclusively for the purposes of performing her duties in Sharpenia.
The amounts paid by Cutlass Inc in respect of Amy’s family travelling to Sharpenia will be subject to UK income tax as
Amy will not be absent from the UK for a continuous period of at least 60 days.