PAYE81515 - PAYE operation: international employments: tax years prior to 6 April 2025 – transitional provisions
Section 690C ITEPA 2003
Section 690C deals with the application of PAYE to payments made to an employee after 5 April 2025, which relate to an earlier tax year in which section 690 applied in relation to that employee.
Where the employee worked both inside and outside the UK in a tax year prior to 2025 to 2026 and:
- the employee was non-UK resident for that tax year,
- that tax year was split year as respects the employee, or
- The employee met the requirements of section 26A ITEPA 2003 (see Employment Income Manual (EIM) EIM40103) and elected to be taxed on the remittance basis, or it appears likely to the employer that the employee has or will make such an election
then an employer making a payment of income in respect of that year may determine the amount that is PAYE income on a best estimate that can reasonably be made.
Directions issued before 6 April 2025
Any HMRC direction issued under section 690 ITEPA 2003 has no effect in relation to tax year 2025 to 2026 or any subsequent tax year. An employer will have to make a new globally mobile employee PAYE notification for any tax year commencing on or after 6 April 2025 (see PAYE81519).