Income Tax (Earnings and Pensions) Act 2003 section 41ZA

Apportionment of earnings

Section 41ZA requires that where an employee performs duties both inside and outside the United Kingdom, their general earnings must be split between UK and non-UK duties on a just and reasonable basis.

  • Applies where an employee's duties are performed partly in the UK and partly overseas
  • General earnings must be apportioned between UK and non-UK duties
  • The apportionment must be carried out on a just and reasonable basis
  • The rules of the relevant Chapter of the Act govern how this determination is made

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