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HMRC internal manual

International Manual

UK residents with foreign income or gains: income arising abroad: Employment - general

An individual who goes abroad to work may remain resident or ordinarily resident in the UK. His earnings may be taxed by the foreign country in which he is working unless the exception provisions in the dependent personal services (income from employment) Article in the agreement exempt him from the foreign tax (see INTM153170).

Although the source of the earnings may, under UK law, be in the UK, usually an agreement, and, for unilateral relief purposes, TIOPA10/S9(3) deems the earnings to arise in the foreign country where he is working. He is entitled to credit for any foreign tax paid on such earnings against the UK tax chargeable on them.