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One of the features of the UK employment income tax rules has long been to afford certain tax advantages to UK resident but non-UK domiciled employees (to 2024/25) who were able to structure their employment arrangements in a particular way.

An employee who is both UK resident and UK domiciled for tax purposes will be taxed on their worldwide income under UK domestic law. This is irrespective of who their employer is and where they perform the duties of their employment¹.

However, an employee who is UK resident but not UK domiciled, and who claims the remittance basis of taxation for a particular tax year (up to 2024/25), will only be taxed on 'chargeable overseas earnings' (see E4.1304) for a tax year to the extent that those earnings are remitted to the UK. For background details on the meaning of domicile and the remittance basis, see Division E6.3.

Earnings from an employment will be 'overseas earnings' if²:

1. Ìý

   •ÌýÌýÌýÌý the remittance basis applies to that employee for the year in question

2. Ìý

   •