½Û×ÓÊÓƵ

Where a non-resident entertainer or sportsperson performs a relevant activity (see E5.802) as an employee of the payer, the earnings for that activity are normally chargeable under ITEPA 2003, s 27 (see E4.115), unless the payment is made indirectly through a third party (see E5.805)¹. In all other cases, where a payment is made that is connected with the relevant activity (so that the deduction of tax at source scheme applies irrespective of the UK tax residence of the payer), the activity is treated for the purposes of the Tax Acts as performed in the course of a UK trade, profession or vocation exercised by the entertainer or sportsperson (unless it is performed in the course of an office or employment). The profits arising from the activity are charged to income tax as trading income² and the non-resident entertainer or sportsperson is treated as carrying on a single, separate trade, profession or vocation within the UK, and is assessed to UK income tax on