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Old 12.03.2007, 14:19
Manolo Manolo is offline
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Re: Zurich London Commute [double taxation question]

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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
But this is exactly Shimla's case. It is NOT an international assignment. Read his posts, he will be working in London 2 full days a week= 104 days a year, greater than 91, therefore ordinarily resident.
I insist, this is the key difficulty. If he gets paid through another country, then IR will say: then why do you come to London so often? Instant audit.
Shimla will have a residence and a family in Switzerland, but having a residence is not the same thing as being resident for tax purposes.
Zurich canton has been known for bugging big banks executives registered in Zug or Schwyz but with "center of interests" in Zurich, but Shimla's situation is not the same and quite more favourable (to him).
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