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UK tax for overseas directors of a UK company

A director who lives abroad and flies in for board meetings can still have a UK tax liability — and the UK company can have a PAYE obligation — for the days worked here. We count the days, apply the treaty, and file what is due.

From £300per director per year · self-assessment and residence review

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Directors are office holders, and UK earnings for duties performed in the UK are taxable here regardless of residence, with no treaty relief in most cases because the directors’ fees article gives the UK the right to tax. If the director is paid by the parent and not by the UK company, HMRC can still require the UK company to operate PAYE on the UK-duty portion. Travel and hotel costs for board meetings are generally allowable for non-resident directors.

Separately, the statutory residence test decides whether a director becomes UK resident on a day count: as few as 16 days can suffice in some circumstances, and 46 to 90 days is the danger zone for people with UK ties. Residence brings worldwide income into UK tax.

We review each director’s pattern of visits, set up an arrangement with HMRC where PAYE applies, register directors for self-assessment where needed, and keep a workday log so the position is defensible.

What’s included

Statutory residence test review and day-count planning
PAYE on UK duties: assessment and HMRC arrangement (including Appendix 4 and short-term business visitor agreements)
Self-assessment registration and return for non-resident directors
Directors’ fees and expenses policy
Treaty analysis for the director’s home country
Annual workday log template

How it works

What happens, in order

Assess

Each director’s role, pay, location and expected UK days.

Arrange

PAYE arrangement or short-term business visitor agreement with HMRC where needed; self-assessment registration where required.

Track and file

Workdays logged; returns filed by 31 January.

When you need this

Who this is for

Every UK subsidiary whose board is abroad, and particularly directors who spend more than 30 days a year in the UK or whose families or homes are here.

Common questions

Does a non-resident director pay UK tax?

On earnings for duties performed in the UK, yes. Board meetings held in the UK are UK duties. Most tax treaties give the UK the right to tax directors’ fees.

Does the UK company have to run PAYE for a director paid abroad?

Potentially yes, on the portion relating to UK duties, unless HMRC has agreed a relaxation. We put the arrangement in place.

How many days can I spend in the UK before becoming resident?

It depends on your ties. Under 16 days is always safe; 16–45 days is safe with no UK home, work or family ties; 46–182 days depends on the number of ties. Over 183 days is always resident.

Can the company pay for my flights to board meetings?

Generally yes, for a non-resident director attending meetings in the UK, without a taxable benefit arising.