Dual citizen who works remotely?

[BlasterBates]

I would imagine it is quite common. Particularly in diplomatic circles. Though there could easily be specific rules for this.

I would imagine it is less common in commercial circles. I don't see how it reduces the tax take, it is direct payment of PAYE. Though it might make it potentially more difficult for HMRC to collect, thus they will be reluctant. It is fairly clear from HMRC that they regard it as a last resort.

PAYE75040 - PAYE operation: PAYE direct payment: when to use PAYE direct payment arrangement

It also brings up the question of Employers NI. Where there is a UK employer (e.g. the established branch) then Er's NI will be due. If the employer is non-eu then it may be the case that ER's NI is not due if the employer does not have a taxable presence in the UK.

I agree it may well be simpler to incorporate and bill the us entity, but there is still the question of how that needs to be dealt with by the IRS.

Having done a lot of cross border working, my experience is that tax authorities put any foreign taxed income under the spotlight.

i.e. they'll be wanting to evidence of when he was in the USA how long etc. then if not I imagine all sorts of questions about exactly what he's doing and why is he on the US payroll if he isn't in the US.

I think it is doubtful that they'll simply wave it through. He'll be claiming tax relief via the Double Taxation Agreement, and it means he'll probably be paying far less tax than he would be if he was a UK employee.

I'm not saying it's not legal but you're going to have to be prepared to run the gauntlet.

Diplomats do do this but then you're employed by the US government and this is black and white.