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Home / Simons-Taxes /Personal and employment tax /Part E4 Employment income /Division E4.13 Internationally mobile employees (expatriates) /Payroll rules for expatriate employees / E4.1329 Special expatriate PAYE arrangements—double taxed UK employees ('EP Appendix 5' agreement)
Commentary

E4.1329 Special expatriate PAYE arrangements—double taxed UK employees ('EP Appendix 5' agreement)

Personal and employment tax

HMRC's internal guidance sets out procedures which allow employers to give relief for foreign taxation when operating PAYE on their employees' earnings1. Note that a special new starter checklist should be completed for all employees included in an expatriate PAYE arrangement.

The procedures apply when a UK employee working abroad is subject to foreign withholding at source, in addition to the normal UK PAYE withholding. This usually happens where the employee remains resident in the UK while working abroad (and subject to tax under ITEPA 2003, s 15 (see E4.1303)) and the foreign country also taxes the earnings for the duties performed in that country. This situation is likely to be more common after the commencement of French income tax withholding on earnings on 1 January 2019. Advance relief for foreign tax paid directly to the foreign authorities can be included in the individual's PAYE tax code2.

The employer's electronic submissions records will be marked by HMRC to show that a double tax relief Appendix

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