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HMRC internal manual

Employment Income Manual

Employment income provided through third parties: remittance basis: transitional rules

Section 554Z11(9) to (11) ITEPA 2003

There are two transitional rules relating to the Part 7A rules and the remittance basis.

They apply if:

  • the ‘relevant tax year’ within the meaning of Section 554Z9 or 554Z10 (see EIM45805 and EIM45811 respectively) is 2007-08 or any earlier tax year that is, before Part 14 Chapter A1 ITA2007 applied, and
  • A was UK resident in that year, but
  • in that tax year, A was either not domiciled in the United Kingdom or not ordinarily UK resident.

If these conditions are met, the two rules below apply

  • Section 554Z9 or 554Z10 applies as if Section 809B ITA 2007 applied to A for the relevant tax year.
  • A resident of the Republic of Ireland does not count as a ‘foreign employer’ for the purposes of Section 554Z9.