The prospect of paying tax twice for the same income is a real concern in our interconnected, globalized world. Professional and personal life often cross multiple borders.
The complexity of international taxation is overwhelming for anyone with financial connections abroad.
Fear not. Double taxation agreements, or “treaties”, are a vital barrier against the financial burden.
Understanding the Double Taxation Dilemma: The Global Tax Tango
When two or more nations assert their rights to tax you, this is the core problem.
It is common for this to happen if your tax residency in more than one jurisdiction has been determined.
If you own rental property abroad and live in the UK, then both places may be taxed.
Double taxation can also result from maintaining income in Britain, while being tax-resident elsewhere.
The simple act of staying more than 183 consecutive days in the UK during a single tax year could inadvertently make you a resident for tax purposes, resulting in double taxation.
Navigating these international tax laws to avoid unnecessary taxation and to ensure that they are adhered by requires care.
Double taxation: How it can offer relief
Double taxation agreements were specifically created to ease this financial burden.
The UK’s agreements with more than 130 countries aren’t just legalese; they protect individuals against being taxed unfairly twice.
The agreements will outline the countries that have the right to tax certain forms of income. They also indicate the country where you can apply for relief and what level you qualify for.
Relief may be provided by a reduction in taxes or by the possibility of claiming a refund.
It’s important to note that tax rates and rules may vary between countries, so you will likely end up paying more tax.
It’s also important to remember that different countries may have different tax year dates.
Double taxation becomes a reality
Double taxation can be a problem in several situations.
Included are:
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Owning property overseas: Both the UK as well as the country where the property is located will tax the rental income.
It is also possible to own property in the UK if you live abroad.
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Income from abroad: If you are a resident of another country, but earn taxable income here in the UK then both countries could tax that income.
- Remote workers’ dilemma: If you work remotely in two or more nations, each country could have tax rights on your income. This is especially true if the residency thresholds are not met, like UK’s rule of 183 days.
If you think you may be taxed more than once, you should seek professional advice.
Double taxation agreements all over the world: The UK network
More than 130 countries are covered by the UK’s network of double-taxation agreements.
The list contains key countries like Australia, Canada China France Germany Hong Kong India Ireland Spain and the United States.
You can find the complete list of agreements and their specifics on the website of gov.uk.
In cases where a DTA is not in place, the UK can offer unilateral relief. This may come as a foreign tax credit through a tax form to make sure that the UK rate of tax will be applied on income earned abroad.
How to avoid double taxation: Decoding Relief
You may qualify for UK tax relief if you live overseas and still earn income in the UK from wages, interest or dividends.
The relief is usually extended to pensions, including the state pension. However, most UK government pensions will only be taxed within Britain.
Gains from shares and other assets are not taxed.
DTAs can also provide relief on the capital gain tax if you sell your overseas property after returning to the UK.
Check the details of the Double Taxation Agreement that applies to you.
Double taxation relief: A guide for step-by-step implementation
You’ll have to complete the form to claim relief from double taxation and send it to your tax authority.
You could live in the UK, or any other country that you are considered to be a resident for tax purposes.
The form will be sent directly to HMRC after they have verified your eligibility or returned to you for sending.
You can find detailed information and forms on the UK Government’s website.
Self-employment and double taxation: IR35 and self-employment
Double taxation agreements also affect the rules governing self-employed contractors (IR35).
These rules are applicable to self-employed people.
If you are unsure about your tax residency, speak to an accountant.
Tax implications of selling overseas investments
HMRC may impose UK Capital Gains Tax if you sold a property abroad for profit while living in the UK.
If a DTA exists, then relief is generally available.
Changes to the non-dom in 2025
Changes to the non-dom regime, initiated by the Conservative government, and later adopted by Labour, have a significant impact on the taxation of individuals who reside permanently outside the UK.
Non-doms who arrive in the UK after April 2025 will pay tax on their income earned abroad for four years.
Some changes are being considered to existing rules.
Is this post taxed twice? This post, Decoding double-taxation agreements for Global Citizens may change as new information unfolds.