Internationally mobile employees

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime Finance Act 2025 (FA 2025) which received Royal Assent on 20 March 2025, implements legislation to abolish the remittance basis of taxation and replace it with a residence-based regime, commencing on 6 April 2025. FA 2025 also replaces domicile as the key factor in establishing liability to inheritance tax. Other changes include amendment of the rules determining excluded property status, the abolition of protected settlements status of offshore trusts, and changes to overseas workday relief.

For information on these changes, see: Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26.

Internationally mobile employees and directors are individuals who work in different jurisdictions around the world (whether concurrently or consecutively). They include:

1. •

   UK residents going overseas to work

2. •

   overseas residents coming to the UK to work, and

3. •

   UK and overseas residents who move in and out of the UK

The taxation of these individuals varies depending upon how they are remunerated