Internationally mobile employees

STOP PRESS: Abolition of non-dom regime and remittance basis of taxation from 2025–26: Finance Act 2025 abolished the remittance basis of taxation and replaced it with a residence-based regime from 6 April 2025. The changes include the introduction of a new Foreign Income and Gains (FIG) regime, and amendments to overseas workday relief. For information on these changes, see Practice Note: The abolition of the remittance basis of taxation from 2025–26.

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

•
UK residents going overseas to work
•
overseas residents coming to the UK to work, and
•
UK and overseas residents who move in and out of the UK

The taxation of these individuals varies depending upon how they are remunerated as well as when and why they spend time in the UK. This subtopic explains the UK income tax and National Insurance contributions (NICs) position in respect of certain issues commonly associated with internationally mobile employees.

Cross-border employment

When employment crosses jurisdictions, tax on an employee's earnings

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

TAKE A FREE TRIAL

Latest Tax News

Tax weekly highlights—21 August 2025

This week's edition of Tax weekly highlights includes: (1) HMRC’s confirmation as to when the decrease in quarterly instalment-related interest rates takes effect, (2) News Analysis of the First-tier Tax Tribunal (FTT) decision in Masters on the UK tax treatment of a transferred pension under a double tax treaty and (3) the publication of the August 2025 Employer Bulletin.

FTT confirms expat’s pension linked to employment despite fund transfer (Masters v HMRC)

Tax analysis: In Masters v HMRC, the First-tier Tax Tribunal (FTT) found that withdrawals from a Self-Invested Personal Pension (SIPP) made by a former UK resident were not taxable in the UK. The necessary connection with past employment remained, despite a transfer of funds from the original scheme. Obiter, the FTT considered that ‘subject to tax’ in a contracting state, as set out in the relevant double taxation treaty (DTT), required the income to be actually taxed there.

Australian top court frees Pepsi from royalty taxes

Law360, London: Australia's top court sided with Pepsi in a long-running tax dispute on 13 August 2025, holding that the beverage giant's soft drink manufacturing agreement with an Australian company did not generate income that would warrant royalty withholding taxes.

Tax weekly highlights—14 August 2025

This week's edition of Tax weekly highlights includes: (1) analysis of the Upper Tribunal’s decision in Elphysic Ltd v HMRC regarding deregistration from VAT under the Ablessio principle; (2) analysis of the First-tier Tax Tribunal’s decision in Clear Pay Payroll Ltd v HMRC to grant an application to postpone payment of disputed VAT pending the outcome of an appeal on the ground of taxpayer hardship; (3) news of the new interest rates that HMRC, Revenue Scotland and the Welsh Revenue Authority will charge on underpaid tax and pay on overpaid tax following the reduction in the Bank of England base rate; (4) news of the first corporate prosecution of the offence of failure to prevent the facilitation of UK tax evasion, which has been brought against an accounting firm; and (5) analysis of the draft Finance Bill 2026 measure for tackling non-compliance in the umbrella company market from John Chaplin, Partner at BDO.