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Introduction

In some circumstances, an individual may be liable to tax in two jurisdictions simultaneously where they are employed in one country but spends time working in another. A double tax treaty between countries can be relied upon in many cross-border situations to exempt an income source from taxation in a particular country. However, double tax treaties are not all identical and care should be taken in determining how treaty provisions may apply to individual employees.

This guidance note covers double tax treaties as they apply to employment income, but it does not cover international social security agreements (for which, see the Social security agreements guidance note).

Treaties are generally set out in a standard format with the same article number addressing the same issue in every treaty. In order to ascertain the employment tax position for an individual employed in one country but spending periods working abroad, the ‘residence’ Article and the ‘income from employment’ or ‘dependent services’