SE40021 - Overseas offices and employments: interaction with Schedule D Case V

Section 18(3) and Section 19(1)1 ICTA 1988

Overseas offices or employments could be said to be “foreign possessions”. But they are specifically excluded from any charge under Case V of Schedule D.

“Tax in respect of income arising from possessions out of the United Kingdom not being income consisting of emoluments from any office or employment.”
Section 18(3) ICTA – Case V of Schedule D

Emoluments from overseas offices or employments are either chargeable under Schedule E or not at all. A decision must be made whether emoluments from such sources are chargeable under Schedule E by reference to the three Cases in Section 19(1)1 ICTA. Guidance on the Cases of Schedule E is provided at SE40002 and SE40003.