Non Dom Double Taxation

[MrsKoala]

If we move to Canada and DH does consultancy in the UK and US does this mean he has to pay tax here as well as Canada?

I'm searching online but getting really confused. If someone could help me i'd be really grateful.

Thanks

I'm not a lawyer and you should talk to someone who is, or the tax offices of England or Canada, but I live abroad and have been confronted with similar problems.

There is a convention between the UK and Canada about who pays tax where. There's a copy of it here

www.fin.gc.ca/treaties-conventions/uk_-eng.asp.

Thanks. I will try to pick thru it. I think i need to talk to a tax lawyer.

Not an expert, but my understanding is that Canada taxes on worldwide income but has a double taxation agreement with the UK. Income earned in the UK would be subject to UK tax but you can offset this against Canadian tax. If your marginal tax rate is higher in Canada you would pay additional tax on your UK income but would not be taxed twice. I live in Canada and have UK income and this is how it works for me.

I don't know about the US but that income would be subject to tax if you were tax resident in Canada. Don't know if there is a double taxation agreement but I would think that it is reasonably common so it should be relatively easy to get advice. We have struggled to get advice on UK-Canada tax issues as we haven't found an advisor that understands both tax systems.

Beware though that not all countries may have a double taxation agreement.
Unrelated, but around 15 years ago I acted for a Danish lady in divorce who was getting maintenance from her UK based husband. He got no tax relief on his maintenance payments, so paid out of net income. In Denmark everyone got taxed on maintenance income, without relief, so full tax was paid in 2 countries on the same slice of income.

They may have changed the rules since then - it was so long ago.

ISeeShapes gives you the answer you're looking for for Canada, but it's right not to just assume that the tax system works between countries so as to automatically remove injustices.