filing tax return with HMRC and dual residency

[wildeep]

Hello, I would appreciate some help in relation to the below situation.

The claimant has dual residency between Greece and the UK. Has a business in Greece and works freelance in the UK. So time is divided between the two countries.

Claimant has paid the full tax due in Greece as if she were only resident there for 16-17.

Now filling in tax return for 16-17 in the UK and wanting some help with this.

Does tax need to be paid to HMRC on the Greek income? If so, how and where should this be declared on the self assessment form?

I appreciate this information is pretty limited but we are somewhat lost. Please ask further questions if we need to clarify anything.

Many thanks for your help.

[RMC]

Is the claimant a Greek national, born & bred there and with a permanent home there, but living / working in the UK because of the economic conditions back home?

[wildeep]

hi, yes she is a Greek national, born and bred there with a permanent home there. She also is a British citizen (she has a British passport).
It's not just because of the economic conditions in Greece, it was more that her career is more established in the UK.

[RMC]

It seems that under the UK/Greece Double Taxation Convention the ‘claimant’ may be tax-resident in Greece, ask her to obtain a Greek certificate of tax residence. If non-resident in the UK under the DTC, she will be liable to UK tax only on income arising here. So, her tax return should show only her UK income, and her foreign tax residence should be mentioned in the ‘white space’.
If she is not tax-resident in Greece, then, subject to the special rules for non-domiciliaries, her tax return should declare her world-wide income, claiming relief for tax paid overseas.
Another possibility is a split year treatment.

[bd6759]

It seems that under the UK/Greece Double Taxation Convention the ‘claimant’ may be tax-resident in Greece, ask her to obtain a Greek certificate of tax residence. If non-resident in the UK under the DTC, she will be liable to UK tax only on income arising here. So, her tax return should show only her UK income, and her foreign tax residence should be mentioned in the ‘white space’.
If she is not tax-resident in Greece, then, subject to the special rules for non-domiciliaries, her tax return should declare her world-wide income, claiming relief for tax paid overseas.
Another possibility is a split year treatment.

It is equally true to say that she may be resident in the UK, There is not nearly enough information to make a call.

If the OP should refer his client to someone with experience in this area.