ITEPA 2003 distinguishes between two main types of earnings: 'overseas earnings' and 'other earnings'. 'Other earnings' are any earnings that are outside the definition of 'overseas earnings'1 and they can be UK-based (ie in respect of duties performed in the UK) or foreign (ie in respect of duties performed outside the UK).
Earnings must be categorised since the category determines the statutory provisions under which the earnings are assessed, which in turn determines whether the earnings are assessed in full on the arising basis or can be assessed on the remittance basis, as well as the deductions that are available to reduce the assessable amount.
Definition of overseas earnings (to 2024/25)
Where a non-domiciled, remittance basis taxpayer does not fall within ITEPA 2003, s 26A (conditions for overseas workdays relief), earnings from the entire duties of an employment with a UK employer become chargeable under ITEPA 2003, s 15 irrespective of where in the world those duties are performed. This is however not the case where earnings are received from an employment which is held with
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Web page updated on 17 Mar 2025 15:29