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The charge on third party earnings ('disguised remuneration')¹ from 6 April 2011 which assesses certain sums and assets not otherwise assessable to income tax and/or NIC can affect non-domiciled employees. The third party income for this purpose can be any payment of money, or the provision of any asset, by a third party other than the employer.

Further anti-avoidance rules apply from 9 December 2016 to disguised remuneration involving third party payments². This anti-avoidance legislation applies to historic and future loan transfers.

The disguised remuneration legislation does not apply to earnings that are part of the normal remuneration benefit package for a senior employee³ and does not apply to certain payments made into, or benefits received from, genuine UK-approved pension savings.

Guidance on the third party earnings charge and the remittance basis earnings of non-domiciled employees is provided in HMRC Employment Income Manual⁴.