D3 Your company has a number of branches and subsidiaries trading outside the UK. The board is about to offer contracts to employees working in UK locations which will allow them to transfer to foreign locations on a temporary basis, with all of their duties being performed outside the UK. There are two contracts being offered - one lasting nine months and one lasting eighteen months. The employees concerned are all currently resident, ordinarily resident and domiciled in the UK.

You are required:

To draft a report to the board on the taxation implications, for the employees, of each of the possible contracts. (CIMA)