Where there is an overseas agency and the client is in the UK, the client is responsible for operating PAYE. This is the result of a rather convoluted series of requirements in ITEPA, as follows:

s. 44(3) says that ‘the worker is to be treated … as holding an employment with the agency, the duties of which consist of the services the worker provides to the client’;

it goes on: ‘all remuneration receivable by the worker … in consequence of providing the services is to be treated … as earnings from that employment’;

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