SE33000 - Foreign Earnings Deduction (FED)

Sections 193, 192A and Schedule 12 ICTA 1988

Introduction

Employees and office holders who are Resident and Ordinarily Resident (see SE42810) in the United Kingdom are chargeable on all emoluments from employment under Case I of Schedule E (see SE40101). However, there are two exceptions from this global charge:

  • An exemption for Foreign Emoluments arising from an employment exercised wholly outside the United Kingdom (see SE40102)and
  • The Foreign Earnings Deduction (FED)

This section deals with the FED. The FED was originally introduced in the 1970’s. It was amended through the 1980’s, most significantly in 1988 and 1991 when special rules for 'seafarers' were enacted. It was finally withdrawn with immediate effect on the 17 March 1998 from all employees and office holders with the exception of 'seafarers'.

This section describes the rules using the following sub-divisions:

General rules for all employees up to 17 March 1998

SE33001General conditions for the period to 17 March 1998
SE33002Amount of the Foreign Earnings Deduction
SE33003Example of a qualifying period that straddles tax years
SE33004Meaning of "qualifying period" for non-seafarers in the period to 17 March 1998
SE33005How to approach the calculation of a "qualifying period"
SE33006Example of "qualifying period" calculation for non-seafarer in period to 17 March 1998
SE33007Qualifying period; days of absence from the United Kingdom
SE33021The year the Foreign Earnings Deduction is given in.
SE33031Meaning of 'duties … performed wholly or partly outside the United Kingdom … '
SE33032Meaning of "United Kingdom"
SE33033Duties of the employment carried out on a ship or aircraft; position to 17 March 1998
SE33034Location of duties; duties performed on ships and aircraft visiting oil and gas rigs
SE33035Location of duties; crown servants
SE33051Attribution of emoluments - example
SE33052Attribution of emoluments; terminal leave pay
SE33053Attribution of emoluments; effect of other deductions
SE33061Treatment of periods of non-residence and terminal leave pay
SE33062Statement of Practice 18/1991
SE33063When periods of non-residence begin and end
SE33064Example of the effect of Extra-statutory Concession A11
SE33070Anti-avoidance legislation - summary
SE33071Anti-avoidance legislation – associated employments
SE33072Anti avoidance legislation: qualifying period straddles tax years
SE33081How to claim and give the Foreign Earnings Deduction
SE33082Verification of dates of absence

Special rules for 'seafarers' up to 17 March 1998

SE33101Rules for seafarers to 17 March 1998
SE33102Meaning of 'seafarer'

Treatment of employees who were working abroad on 17 March 1998 but had not completed a qualifying period

SE33201Foreign Earnings Deduction: withdrawal on 17 March 1998
SE33202Example of employees working abroad on 17 March 1998 who had not completed a qualifying period of at least 365 days

FED for 'seafarers' introduced with effect from 17 March 1998

SE33221Meaning of 'seafarer' and 'ship' on and after 17 March 1998
SE33222Meaning of 'offshore installation' on and after 17 March 1998
SE33223Examples of 'offshore installation' and ships on and after 17 March 1998
SE33301Example of seafarer’s calculation of qualifying period including 17 March 1998