The rules as to the identification of taxable earnings vary according to the residence and domicile status of the employee concerned, the residence of the employer and whether the duties are performed in the UK or abroad. Where the remittance basis (see E4.120, E6.324B–E6.332A) applies to general earnings, the position further depends upon whether the employee does or does not meet the test set out in ITEPA 2003, s 26A ('the section 26A test'), which in broad terms can be met only where the employee has a recent history of non-UK residence for three consecutive tax years (see E4.109).
The section 26A test came into effect
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