UK domicile with unremitting foreign income from a country with double taxation treaty
I am in a full time employment in UK but work most of the time remotely (from abroad). The fact that I spend time abroad is unrelated to my employment - my profession allows it and it's cheaper to live there.
According to Statutory Residence Test, I am UK resident because I meet none of the overseas tests and meet the automatic UK test about full-time employment.
I have a second income in the another country. This income is from a freelance work. The work is done as a non UK sole trader, outside UK, for a non UK company and the income is paid into a non UK bank account.
There is a double taxation treaty between The UK and the other country:
I assume that, as a freelancer, my case falls under article 7, Business profits:
The profits of an enterprise of a Contracting State shall be taxable only in that
State unless the enterprise carries on business in the other Contracting State
through a permanent establishment situated therein. If the enterprise carries on
business as aforesaid, the profits of the enterprise may be taxed in the other State
but only so much of them as is attributable to that permanent establishment.
Does this mean that as long as don't bring the foreign income into UK, I don't have to pay taxes on it?
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