Foreign employment ― dual contracts

Produced by a Tolley Personal Tax expert

Personal Tax

Guidance

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. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in Finance Bill 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

Introduction

Employees may have two contracts of employment, one with an employer who is not resident in the UK, and one with a UK resident employer.

It is of course sometimes the case that these employers are unconnected, and the individual has simply accepted two posts, one abroad and one in the UK. For instance, a person might be employed by Oxford University and by the Sorbonne, with different responsibilities under each contract.

Often, however, the employers are associated, with the employee’s duties divided into those relating to an overseas employment and those related to the UK employment. Historically, this type of dual contract was particularly

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