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Where is trade carried on?

Is trade carried on where the worker resides or where the organisation engaging him is based?

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My client lives in South Africa.  He is not resident in the UK and this has been the case for a number of years.

He is a self employed journalist.  Much of his work is carried out for UK based news agencies or charities who contract to use his services for a short while to cover a specific issue.  Other work arises via UK based agencies.  All of the work however is carried on in South Africa and further afield on the continent.

For the purposes of S6 (2) ITTOIA 2005, does the fact that all of the work is carried out overseas, mean that the trade is carried on outside of the UK?  

Many thanks


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26th Mar 2019 16:04

You don't say whether your client was a self employed journalistwhen he was UK resident, but assuming that this was the case, any UK business would have been deemed ceased when he left the UK, and a new one begun in SA. Assuming that all duties are carried out outside the UK, and client does not visit the UK for any professional purpose or significant length of time during the year, the business will be an overseas business.

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