Dual Contracts - HMRC Tighten the Noose

    From 5 April 2014 HMRC intends to target contrived arrangements which create “artificial divisions between the duties of a UK employment and an employment overseas in order to obtain a tax advantage”. The new legislation is expected to bring in £245m over the next 4 years. It remains unclear why such new legislation is even needed (particularly in an era of purported tax simplification) as there are already provisions in ITEPA to prevent any artificiality. There is a real danger that these rules will hit genuine division of contracts.