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HMRC internal manual

Employment Income Manual

Employment income: basis of assessment for general earnings: employees who are, or have been, not resident not domiciled in the United Kingdom

Chapters 4 and 5 of Part 2 ITEPA 2003

If an employee or office holder receives earnings for a year when they are (or were) not resident or not domiciled in the United Kingdom, the amount received may not be, or may only partly be, chargeable to tax. Detailed guidance is at EIM40001onwards. In general you will find that, in cases involving non-UK residence or domicile:

  • some earnings are taxable when they are received (see EIM42260 onwards)
  • some earnings are taxable when they are received in the United Kingdom (see EIM42370) and
  • some earnings (mainly, those relating to overseas duties) may not be taxable at all.

Remember that it is the employee’s residence and domicile status in the year that the earnings are for that determines whether (or to what extent) the earnings are chargeable to tax (see EIM42201).