Income Tax (Earnings and Pensions) Act 2003 section 554Z10

Remittance basis: A met section 26A requirement

Section 554Z10 deals with how employment income arising from third-party arrangements is taxed on the remittance basis where the individual met the section 26A requirement for the relevant tax year.

• The section applies where the remittance basis applied to the individual (A) for the relevant tax year and A met the section 26A requirement for that year.
• Only the overseas portion of the employment income — that is, the part not relating to duties performed in the UK — is subject to the remittance basis; it becomes taxable specific income only when and to the extent it is remitted to the UK.
• Where the relevant step falls under the 2017 loan charge provisions, the overseas portion is taxable specific income in the year the step is treated as taken, provided it was remitted in that year or any earlier year.
• The split between UK-duty income and overseas income must be determined on a just and reasonable basis, and any remittance occurring before the employment begins is treated as remitted in the tax year the employment starts.