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The Foreign Income and Gains regime: employer considerations

The UK is likely to become more attractive in the short term for overseas employees but less attractive in the medium to long term, Claire Murray and Nisus Larsen (Alvarez & Marsal) explain.

The new Foreign Income and Gains (FIG) regime

Adetailed analysis of the new legislation has already been provided in this journal (see ‘Non-doms post-Budget: where are we now?’ (Helen McGhee and Lynnette Bober) Tax Journal 8 November 2024) so the focus of this article is the expected impact of the new regime on employers and their employees and the practical steps which employers may wish to undertake now.

The FIG legislation will be inserted as ITTOIA 2005 Part 8 Chapter 5 s 845A onwards and employment income will be covered by ITEPA 2003 new Chapter 5C s 41M onwards. Finance Bill 2024/25 removes reference to domicile within tax legislation by replacing ‘not domiciled’...

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