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HMRC internal manual

Employment Related Securities Manual

International from 6 April 2015: remittance - from 6 April 2015: special mixed fund rules for certain employment cases

HMRC’s Statement of Practice 1/09 (SP1/09) provided an administrative easement for employees who were resident but not ordinarily resident in the UK and had a single contract of employment covering duties carried out in the UK and overseas. It enabled them to apply the remittance basis rules on a simplified basis to certain “mixed funds” containing income and certain other funds including some proceeds from employee share schemes.

Finance Act 2013 introduced the Special Mixed Fund rules which give effect to SP1/09 in legislation.

Frequently Asked Questions on the new Special Mixed Fund rules legislation in ITA07/S809RA to ITA07/S809RD are available at EIM40307.