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Internationally mobile employees (expatriates)

E4.1301 International mobile employees—overview

The non-UK domicile basis of taxation is abolished with effect from 6 April 2025, as confirmed in Finance Bill 2025¹. With this, all associated tax treatments including the remittance basis of taxation and overseas workday relief, are either removed or substantially revised. A summary of the new regime applying from that date, together with a number of transitional measures which apply to those individuals who have employment income and who have established a non-UK domicile before that date, is provided at E4.1312A. Details of the rules which have applied to 5 April 2025 are also been retained for reference. It is likely these outgoing rules will remain relevant for some time: one example being where overseas income of a non-UK domiciled individual arises before 6 April 2025, but which has not been remitted to the UK until after that date.

Internationally mobile employees and directors are those individuals who work in different jurisdictions around the