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Old 12.03.2007, 06:25
Richard Richard is offline
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Re: Zurich London Commute [double taxation question]

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BTW Switzerland does not have that resident, ordinarily resident, or domiciled distinction.
Oh but yes it does... At least it differentiates between resident and domiciled and does this through the location where your centre of life is. Granted this is generally for determining which canton you will pay tax in but it **can** also be applied to which country..

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If you are not a resident, spend less than six months there, and pay taxes to someone else they will leave you alone.
Which of course is perfectly correct they will not even trouble you if you do not pay tax at all unless you are resident, however this is not the case in this case as they will be Swiss resident and therefore liable for Swiss tax on global income irrespective of taxes paid elsewhere.
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The difficulty in this case is the strict UK rules for determining residence for tax purposes.
Actually the real difficulty is if you are paid out of the uk. There are no real problems with international assignments paid out of a foreign country as long as the person in the UK has no connection to the uk. As a declared non-uk resident you need to work a hell of a lot in order to qualify to pay uk tax... present 183 days in a year or 91 days averaged over 4 years
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