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The basis of assessment of earnings (see E4.104) often depends on whether the duties of the employment are performed wholly or partly outside the UK. Where, in substance, the duties of an employment fall to be performed abroad (ie outside the UK), any duties performed in the UK which are merely incidental to those performed abroad are treated as performed abroad¹. Note that this rule does not apply in the context of the seafarers' deduction² (see E4.123, E4.753). There is, however, no equivalent provision treating duties performed abroad as incidental to those performed in the UK.

A further exception may apply in the case of an individual who was forced to remain in the UK due to coronavirus travel restrictions. This easement, which can be applied up to 5 April 2022, may allow the individual to treat income in such periods as if it were earned outside the UK, so long as the income is already taxable in the home state. Further information may be found in HMRC Agent