I have a client who seems to fit within TCGA 1992 s223(3)(b), but I'm concerned about the wording "all the duties of which were performed outside the UK".
Especially when read in conjunction with cg65040 which talks about "you should not ignore any duties which are in practice performed in the UK even if they are only incidental to the main duties performed outside the UK". And also taking into account how uncompromising HMRC can be on this issue when it comes to dual contract cases.
Does anyone have any experience of HMRC jumping on a taxpayer sending the occasional work email etc. whilst in the UK as being a reason to deny s223 relief?