½Û×ÓÊÓƵ

STOP PRESS: The remittance basis is to be abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. See Simon's Taxes E6.300 for full details. The commentary below is impacted by these changes, which are to be legislated in Finance Act 2025.

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 (the concept of domicile is abolished for income tax purposes from 6 April 2025) 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 (abolished and replaced with the foreign income and gains regime from