
HMRC have published a new Statement of Practice (SoP) 1/09.
Statement of Practice (SoP) 5/84: Employees resident but not ordinarily resident in the UK: general earnings chargeable under s. 25 and 26 ITEPA 2003 is to be withdrawn from 6 April 2009 and replaced with new SoP 1/09: Employees resident but not ordinarily resident in the UK: General earnings chargeable under Sections 15 and 26 Income Tax (Earnings and Pensions) Act 2003 (ITEPA) and application of the mixed fund rule under Sections 809Q onwards of the Income Tax Act 2007 (ITA), from that date.
The new SoP sets out how HMRC will treat transfers made from an offshore account holding only the income or gains relating to a single employment and the apportionment of earnings where an employee is taxed on the remittance basis.
The text of the new SoP is available on the HMRC website at http://www.hmrc.gov.uk/practitioners/sop.pdf.
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