Non-dom working overseas at a company he doesn't own

[Elijah Ferraris]

Hi - I posted here before on working overseas at my own offshore company while living in the UK as a non-dom - which I understand is problematic due to control & management issues.

What happens if a non-dom works overseas at a company he doesn't own at all? (I don't mean that there fake shareholders/directors - but rather an actual 3rd party that wants to hire the non-dom)
For example - let's say the job is frontal instruction - giving a course to a class - something that is clearly cannot be done remote while I'm in the UK.

In that case - if salary for this job is not remitted to the UK - will it be fully exempt from tax?
One point is that most likely negotiations for obtaining such a job may be done in the UK from time to time (in emails/phone calls) - but the payment is done only for the actual frontal instruction on site (i.e. there is no services given or anything else payable while in the UK)

I do know that there is something that is called Overseas Workday Relief, that basically allows for something similar, but as long as the employer is UK based (and then only for up to 3 tax years)
But if the employer is offshore - can any income be exempted in the same way (but for as long as I'm non-dom)?

Thanks!

 

[CreamSoda]

Your previous posts suggest a possibility of Malta, so I have taken the UK - Malta tax treaty as an example. I would have loved to post a link for your convenience, but an overzealous mod banned me yesterday for doing so. This treaty takes precedence over domestic law, and provides for which jurisdictions have the right to tax certain incomes/profits etc. Paying particular attention to Article 14 (Independent Personal Services) and Article 15 (Dependent Personal Services), (which are the two I feel are most relevant to the limited information provided), would provide clarity as to some suitable options available to you. However, I suggest reading the whole treaty between the UK and other country you are considering, to learn about possible planning opportunities and pitfalls.

You confirm your non-dom status, but I am unsure of your residency status. OWR would only benefit you if you are non-UK resident for either 3 years prior or 2 years after.