Can anyone give me information on double taxation agreements between France and the UK?
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I work at a University and we have some visiting researchers coming over for 4 x two weekly periods to engage in research. They will be being paid their salary by the company in France but I wanted to know whether we should tax them as according to my interpretation of Article 21 of the double taxation agreement, they should not pay tax in the UK. I would appreciate any guidance on this as I am not sure if we are following the correct procedure. Thanks in advance.
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Answer:
If the university is not paying them to conduct any research then I'm not quite sure why you believe that that you have any reason to deduct PAYE from them - there is no income payable to them by your institution for to make deductions from. Article 21, in my opinion, is irrelevant. If you were the conduit through which the payments are made, if Article 21 did not exist then you would. I believe your interpretation is correct, but to be 100% I would contact the tax office responsible for your universities Payroll. Ask to speak to an Inspector directly - call handlers will not be able to deal with this query.
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Other answers
I believe they are covered by the Double Taxation Treaty, but you should be asking your Tax Office, not on here! Only HMRC can give rulings like this.
fengirl2
The only countries I'm aware of that double tax you are the United States and New Zealand, requiring you to report your entire income no matter where you've earned it. I.e. if an American lives and works in France he will have to pay both French and American taxes if you're making above $75000 per annum. If you're an Italian living and working in the U.K for example, then you will only pay the U.K. taxes. If you're a British citizen living in Saudi Arabia then you will pay no taxes at all because that country has no income tax.
Sven B
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