Employment Income Manual

EIM43501 - Globally mobile employees: Overview

This ‘Globally mobile employees’ section of the Manual covers problems that arise for employees who come to, or go outside, the UK to work.

Although not a statutory term, for the purposes of this guidance where an employee comes to, or goes outside, the UK to work they are referred to as a Globally Mobile Employee (“GME”).

As set out in EIM40000+ and ERSM162000, an employee’s residence status in a tax year can affect their liability to income tax on their general earnings which are ‘for’ that tax year, or any employment related securities income which is treated as accruing during that tax year.

For example, when an employee is not UK resident in a tax year and performs their employment duties both in and outside the UK during that tax year, ordinarily only their employment income which relates to their UK duties will be chargeable to UK tax.

UK residence is determined by reference to the statutory residence test. For more information, please go to HMRC manual RFIG20000.

Where an employee is globally mobile, this can affect the operation of PAYE. EIM43525+ provides an overview of some of the interactions and what this may mean for employees, while PAYE81500+ provides further guidance on the implications for employers when operating PAYE.

Where an employee becomes UK resident for the first time, or after a continuous ten-year period of non-residence, they may be a qualifying new resident (see RFIG44000), so that they may be eligible for Overseas Workday relief, see EIM43555+ for further guidance.

GMEs may be subject to both UK income tax and foreign tax on their employment income. Where this occurs, they may be able to claim double taxation relief, see INTM160000 for further guidance.

There are special rules which can apply to the travelling expenses of globally mobile employees, if certain requirements are met. EIM34000+ provides further guidance for employees travelling to work outside the UK and EIM35000+ provides further guidance for employees travelling to work inside the UK.