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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. See Simon's Taxes E6.300 for full details. Liability to inheritance tax (IHT) will also move to a residence-based regime (rather than one based on the individual's domicile) from 6 April 2025. See Simon's Taxes I9.200 for full details. The commentary below is potentially impacted by one or both of these changes, which are to be legislated in Finance Act 2025.

General principles for internationally mobile employees

The rules for determining securities income arising from an employment-related security (ERS) depend on the type of employment security in question. Once the income is ascertained, it is then apportioned according to relevant periods of non-residence or use of remittance basis by internationally mobile employees. (Note that from 6 April 2025, the remittance basis will be replaced by the Foreign Income and Gains (FIG) regime, see Section 6). The apportionment is discussed further below, after the following summary of how ERS