SE40031 - Meaning of "foreign emoluments"

Section 192(1) ICTA 1988

Section 192(1) ICTA 1988 provides a statutory definition of 'foreign emoluments'. They are:

• the emoluments of a person who is not domiciled in the United Kingdom
• from an employment with a person who is not resident in and resident outside of the United Kingdom

It does not include the emoluments of an employee who is resident in the United Kingdom from an employment with a person who is resident in the Republic of Ireland.

Foreign emoluments may be taxed in the same way as other emoluments. Their special status becomes significant when the duties of the employment that gives rise to the foreign emoluments are performed wholly outside of the United Kingdom. In these circumstances the foreign emoluments are excepted from Case I of Schedule E and charged under Case III if they are remitted to the United Kingdom.

Further guidance is provided on the pages listed below: