At the start of the Covid-19 pandemic in 2020 HMRC set out guidance that non-UK resident employees stranded in the UK because of coronavirus travel restrictions would not be taxed on earnings for duties performed in the UK after their planned departure date, provided they are taxed in their home state.
This easement will end on 5 April 2022 as travel restrictions have been largely withdrawn and self-isolation regulations were removed on 24 February, meaning it is no longer ‘just and reasonable’ to treat these duties as performed outside the UK.
Assignees that are non-UK residents, where ordinarily any days they spend working in the UK will be treated as days on which they performed duties in the UK. From 6 April 2022, this will be the case even if they are prevented from leaving the UK as a result of coronavirus related circumstances.
If you have any questions, please do reach out to your BDO team.