Postby Brightonian » Wed Oct 03, 2018 1:53 pm
I have a little more research and tried to get my head round this. Under the treaty, he will be UK resident, as he is a UK national, so it just depends on how we interpret Article 15. He would only be taxable in the UK except where the employment is carried out in Italy. it was carried out in Italy and therefore Italy may tax it. Does that mean the UK taxes it and Italy taxes it also, so I have to claim tax credit relief? Or does that mean only Italy taxes it? It is ambiguous. If it said that Italy may tax it also, at least it would be clear that it is taxable in both countries but, as it is, I can't see whether it's a case of the income being exempt from UK tax or being taxable subject to tax credit relief. I should be really grateful if someone could just interpret that article for me. I can't find anything online.