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Virtually here? or there?

Taxation of non-UK resident director's fees received from a UK resident company.

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I have a client who is non-uk resident who is a non-executive director of a UK resident limited company.

In the 2018/2019 tax year he attended board meetings in the UK - and I am happy that his 2018/2019 directors fees are taxable in the UK.

During 2019/2020 however he did not physically attend the board meetings - he "virtually" attended by way of video-link from his home abroad.  This being the case, he did not actually undertake any work in the UK during the year - so will that mean that his director's fees are not liable to UK tax?

My instinct is yes - but deep down, part of me thinks that HMRC aren't going to make it that easy.

Any guidance would be much appreciated.  Thanks.

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By carnmores
01st Dec 2020 15:43

you've opened up a new line of attack for HMRC here ! if he was in telephone attendance he would in my opinion not be taxed so why should he because he appears live on screen, no difference in my view. the work is carried out where he is?

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By I'msorryIhaven'taclue
01st Dec 2020 16:19

So could that be the difference between telephone attendance versus Whatsapp attendance versus Skype attendance versus Microsoft Video Call attendance?

I guess there's a progression, but just where would the line be drawn?

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