After section 15 insert—

“15ANon-resident’s staff are UK client’s employees for section 15 purposes

(1)

Subsection (5) applies if each of conditions A to C is met.

(2)

Condition A is that a person (“F”) performs in the United Kingdom, for a continuous period of 30 days or more, duties of an office or employment.

(3)

Condition B is that the office or employment is under or with a person who—

(a)

is not resident in the United Kingdom, but

(b)

is resident outside the United Kingdom.

(4)

Condition C is that the duties are performed for the benefit of a person (“P”) who—

(a)

is resident in the United Kingdom, or

(b)

carries on a trade, profession or vocation in the United Kingdom.

(5)

Section 15 of this Act applies as if P were F’s employer, but only so as to enable P to be required to make a return of F’s name and place of residence.”