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Internationally mobile employees and directors are those individuals who work in different jurisdictions around the world (whether concurrently or consecutively).

The taxation of employment income is based on the rules in ITEPA 2003, ss 1–554Z21, which assess earnings according to three main UK territorial connecting factors.

The connecting factors for employment income are:

1. Ìý

   •ÌýÌýÌýÌý the employee's status under the principles of residence and domicile for tax purposes

2. Ìý

   •ÌýÌýÌýÌý the place that the duties of the employment are performed, and

3. Ìý

   •ÌýÌýÌýÌý the employer's residence status

The optional remittance basis for certain non-UK earnings also determines the amount assessable to income tax. An employee who is UK resident but not UK domiciled, and who claims the remittance basis of taxation for a particular tax year, will only be taxed on 'chargeable overseas earnings' or 'foreign earnings' for a tax year to the extent that those earnings are remitted to the UK (ITEPA 2003, ss 22, 26, 26A).

It is assumed that the personal tax position of the globally mobile