Part 2

Employment income: charge to tax
Chapter 5C

Relief for new residents on foreign employment income

Qualifying foreign employment income

Qualifying foreign third party income
41V
1
For the purposes of this Chapter, “third party income” is an amount that counts under Chapter 2 of Part 7A (treatment of relevant step for income tax purposes) as employment income in respect of an employment.
2
Third party income is “qualifying third party income”—
a
if it is in respect of an employment the duties of which are performed wholly or partly outside the UK during the qualifying year, and
b
to the extent that the value of the relevant step that counts as employment income (see section 554Z3) is—
i
“for” the qualifying year determined in accordance with section 554Z4(2), and
ii
if the qualifying year is a split year as respects the individual, attributable to the UK part of the year.
3
Any attribution required for the purposes of subsection (2)(b)(ii) is to be done on a just and reasonable basis.
4
Qualifying third party income is “qualifying foreign third party income” to the extent that it is not in respect of duties performed in the United Kingdom.
5
The extent to which qualifying third party income is not in respect of duties performed in the United Kingdom is to be determined on a just and reasonable basis.
Pt. 2 applied (E.W.S.) (31.3.2017) by The Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017 (S.I. 2017/353), reg. 1(1), Sch. 1 para. 4(3) (with reg. 2(4)(5))
Pt. 2 applied (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), ss. 969(4)(a), 1329(1) (with Sch. 2 Pts. 1, 2)
Pt. 2 Ch. 5C inserted (20.3.2025 for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), s. 38(1)(3) (with Sch. 8 Pt. 3)