UK 183 day rule

Nov 16, 2012
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Hi all,

My first time here and I am here because I can't see through this issue anymore, neither can my tax consultant.

Picture this:
Client lives in Germany, family lives in Germany, client starts work in UK (three month contract) of course he will be taxed in Germany. So far, so good (or not).
Client exceeds 183 days in UK, will now be taxed in UK from day 1. Still no big problem. (Place of work overrides place of residence - here opinions already differ).
Client actually owns a Ltd. with which he is employed and which pays him. Ltd. is registered in Germany and invoices UK company where client took assignment. So not all three criteria for the 183 day rule are fulfilled (paying company is in Germany) OR ARE THEY?
The German Ltd. also has other income from German assignments.
To make matters worse, the client is director of the Ltd....
There are about a hundred opinions on where tax has to be paid and I am at total loss.
Any help would be highly appreciated!



VIP Member
Aug 26, 2011
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Issues involving residence and domicile are notoriously complicated, and the situation you have does seem quite complex. Where are you based?

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