Finance Act 2025

Amendments of ITEPA 2003 connected with end of remittance basis U.K.

3 (1) ITEPA 2003 (employment income: charge to tax) is amended as follows.

(2) In section 6 (nature of charge to tax on employment income), in subsection (3)—

(a) in paragraph (a), omit “and domicile”;

(b) in paragraph (aa), for “applies” substitute “applied”.

(3) In section 20 (taxable earnings under this Chapter), for subsection (1) substitute—

“(1) This Chapter contains provision for determining how much of the following are taxable earnings from an employment in a tax year—

(a) general earnings that are for a tax year for which section 809B, 809D or 809E of ITA 2007 (remittance basis) applied to the employee (being a tax year before tax year 2025-26), and

(b) general earnings that are for a tax year for which the employee is non-UK resident.”

(4) In section 22 (chargeable overseas earnings for year when remittance basis applies and employee outside section 26)—

(a) in the heading and in subsection (1)(a), for “applies” substitute “applied”;

(b) in subsection (1)(b), for “does not” substitute “did not”.

(5) In section 23 (calculation of “chargeable overseas earnings”), in subsection (2)—

(a) in paragraph (a), for “applies” substitute “applied”;

(b) in paragraph (aa) for “does not” substitute “did not”;

(c) in paragraph (b) for “is” substitute “was”;

(d) in paragraph (c) for “are” substitute “were”.

(6) In the italic heading before section 25, for “meet” substitute “met”.

(7) In section 26 (foreign earnings for year when remittance basis applies and employee meets section 26A requirement)—

(a) in the heading, for “applies and employee meets” substitute “applied and employee met”;

(b) in subsection (1), in the opening words—

(i) for “applies”, in the second place it appears, substitute “applied”;

(ii) for “meets” substitute “met”.

(8) In section 41F (taxable specific income: internationally mobile employee etc), in subsection (2)(a), for “applies” substitute “applied”.

(9) In section 41H (section 41F: chargeable and unchargeable foreign securities income)—

(a) in subsection (4)—

(i) in paragraph (a), for “applies” substitute “applied”;

(ii) in paragraph (b) for “does not” substitute “did not”;

(iii) in paragraph (c) for “is” substitute “was”;

(iv) in paragraph (d) for “are” substitute “were”;

(b) in subsection (7)—

(i) in paragraph (a), for “applies” substitute “applied”;

(ii) in paragraph (b) for “meets” substitute “met”;

(iii) in paragraph (c) for “are” substitute “were”.

(10) In section 271 (limited exemption of removal benefits and expenses: general)—

(a) in subsections (2)(a) and (2)(b), for “applies” substitute “applied”;

(b) in subsection (2)(b), for “meets” substitute “met”.

(11) In section 554Z9 (remittance basis: A does not meet section 26A requirement)—

(a) in the heading, for “does not” substitute “did not”;

(b) in subsection (1)—

(i) in paragraph (b) for “applies” substitute “applied”;

(ii) in paragraph (c) for “does not” substitute “did not”;

(iii) in paragraph (d) for “is” substitute “was”;

(iv) in paragraph (e), for “are” substitute “were”.

(12) In section 554Z10 (remittance basis: A meets section 26A requirement)—

(a) in the heading, for “meets” substitute “met”;

(b) in subsection (1)(b), for “applies” substitute “applied”;

(c) in subsection (1)(c), for “meets” substitute “met”.

(13) In section 576A (temporary non-residents), in subsection (5), for “applies” substitute “applied”.

(14) In section 698 (PAYE: special charges on employment-related securities), in subsection (8), for “remittance basis” substitute “internationally mobile employees”.

(15) In section 700 (PAYE: gains from securities options), in subsection (7), for “remittance basis” substitute “internationally mobile employees”.

(16) In section 700A (employment-related securities etc: remittance basis), in the heading, for “remittance basis” substitute “internationally mobile employees”.