I have a client who is based in South Africa who has a number of let properties in the UK.
His wife now has a small letting agent business in the UK acting as a lettings agent, in part for her husband’s properties, and in part for some 3rd parties, so it seem to be genuine.
Generally a trade carried out in the UK is taxable in the UK. In this case SOME of the trade is conducted whilst in SA and SOME in the UK which I think means at least part of the trade is taxable in the UK, (not looking forward to working that out, but probably falls under the personal allowance, for now)
Am I missing a rule around the fact this involves land and property based solely in the UK which makes all of the income taxable in the UK? If so, where should I be looking? I think I might be getting confused with the VAT rules and possibly some wishful thinking on my part about not having to split it.
Looking at the DTA between the UK and SA, Article 6 deals with land and states "The provisions of paragraphs 1 and 3 [which say it may be taxable where the land is] of this Article shall also apply to the income from immovable property of an enterprise."