Income Tax (Earnings and Pensions) Act 2003 section 690

Employee non-resident etc.

Section 690 sets out the PAYE treatment of payments made to internationally mobile employees who work both inside and outside the UK and who may be non-UK resident or in a split year.

• From 2025-26 onwards, an employee is "internationally mobile" if they work or are likely to work both inside and outside the UK during the tax year, and they are either non-UK resident for that year or it is a split year for them.
• Where the employer cannot determine what proportion of a payment constitutes PAYE income because of the employee's internationally mobile status, the entire payment must be treated as PAYE income and subjected to PAYE deductions.
• Treating the full payment as PAYE income does not alter the employee's actual tax liability — any overpayment of tax can be reclaimed, and any underpayment remains due.
• Payments made on behalf of and at the expense of the employer (or a connected person) count as employer payments, and where sections 689 or 689A apply, references to the employer are read as references to the "relevant person" defined in those sections.