Part 2Trading income

Chapter 2Income taxed as trade profits

Trades and trade profits

13Visiting performers

1

This section applies if an entertainer, sportsman or sportswoman of a prescribed description (a “performer”)—

a

is non-UK resident in a tax year, and

b

performs a relevant activity in the United Kingdom in the tax year.

2

If a payment or transfer connected with the relevant activity is made, the performer is treated for income tax purposes as performing the relevant activity in the course of a trade, profession or vocation carried on in the United Kingdom.

3

It does not matter whether the payment or transfer is made to the performer or anyone else.

4

Subsection (2) does not apply—

a

so far as the performer would otherwise be performing the relevant activity in the course of a trade, profession or vocation carried on in the United Kingdom, or

b

if the relevant activity is performed in the course of an employment or office.

5

If a payment or transfer connected with the relevant activity is made to —

a

a person other than the performer, and

b

that person is of a prescribed description,

the payment or transfer is treated for income tax purposes as made instead to the performer in the course of a trade, profession or vocation carried on in the United Kingdom.

6

Subsection (5) does not apply in such circumstances as may be prescribed.

7

If—

a

income tax is chargeable on profits arising from payments or transfers (made to any person), and

b

the payments or transfers are connected with the relevant activity,

the tax is charged as if the payments or transfers were received in the course of a separate trade, profession or vocation (distinct from any other trade, profession or vocation carried on by the performer).

8

In this section and section 14—

  • payment” means a payment from which income tax is to be deducted under section 555(2) of ICTA,

  • prescribed” means prescribed by regulations,

  • regulations” means regulations made by the Treasury,

  • relevant activity” means an activity of a prescribed description, and

  • transfer” means a transfer in respect of which income tax is to be accounted for under section 555(3) of ICTA,

and a payment or transfer is connected with a relevant activity if it has a connection of the prescribed kind with that activity.