Income Tax (Earnings and Pensions) Act 2003 section 554Z9

Remittance basis: A did not meet section 26A requirement

Section 554Z9 deals with how employment income provided through third parties is taxed on the remittance basis where the individual did not meet the section 26A requirement, was employed by a foreign employer, and performed all duties outside the United Kingdom.

• The section applies where the remittance basis applies to the individual for the relevant tax year, they did not meet the section 26A requirement, their employer is a foreign employer, and all employment duties were performed outside the UK
• Employment income arising from a relevant step is only taxable as "taxable specific income" to the extent it is actually remitted to the United Kingdom, rather than being taxed as it arises
• Special rules apply to loan-related relevant steps under Schedule 11 to Finance (No. 2) Act 2017, where income is taxable in the year the step is treated as taken, but only so far as it has been remitted in that year or any earlier year
• Where the individual also has associated employments with duties partly performed in the UK, the amount qualifying for the remittance basis is restricted to a just and reasonable proportion