SE40222 - Schedule E Case II: calculation of emoluments arising from duties performed in the United Kingdom: example
Section 19(1)1 ICTA 1988
A US citizen is assigned to the United Kingdom by the US
employer for a period of 2 – 3 years. Residence status is
self-determined to be Resident but Not Ordinarily Resident in Years
1 and 2.
The employee is Head of European Operations, a post that
requires a proportion of the duties to be performed outside the
United Kingdom. In consequence emoluments are likely to be split
between Cases II and III of Schedule E. Emoluments arising from
duties performed offshore are potentially chargeable under Case III
is they are “received” in the United Kingdom within the
definition of Section 132(5) ICTA.
Remuneration for Year 1 is reported as below. In the Year,
80/240 workdays were spent in the United Kingdom
| Salary | £100,000 |
| Bonus | £100,000 |
| Car provided by the employer | £5,000 |
| House provided by the employer | £10,000 |
| School fees paid in the US | £10,000 |
| Total | £225,000 |
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|
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| Case II = £225,000 x 80/240 | £75,000 |
| Case III = 225,000 - 75,000 | £150,000* |
*chargeable if remitted to the United Kingdom
