EIM11825 - PAYE: special type of payer or payee: internationally mobile employees

Section 690 ITEPA 2003

From 6 April 2025, section 690 applies in relation to an employee if during a tax year they are 'internationally mobile'. Section 690 provides that en employee is 'internationally mobile' if they work both in the UK and abroad in a tax year, and 

  • the employee is, or is likely to be a non-resident during that tax year, and
  • the year is, or is likely to be, a split year for the employee 

Where an employee is internationally mobile, the employee may be taxable on only part of their employment income. In these circumstances some of their income may not be PAYE income (see PAYE81513 for further guidance).Ěý

As a result, an employer may be unable to ascertain the extent to which this payment is PAYE income at the time it is made, because the employee is internationally mobile. Where this happens, the payment is an 'uncertain payment' for the purposes of section 690.

Where an employer makes an uncertain payment, section 690 treats the entire payment as being PAYE income.

From 6 April 2025 where section 690 applies in relation to an employee during a tax year, the employer, or other person designated by the employer, can notify HMRC of their intention to treat part of any uncertain payment as not being PAYE income (see PAYE81514).Ěý

Where an employer makes a notification for a tax year to treat part of any uncertainty as not being PAYE income, the relevant employee will need to complete a Self-Assessment tax return for that tax year.Â