Commentary on Sections Glossary Part 2: Employment income: charge to tax Section 24: Limit on chargeable overseas earnings where duties of associated employment performed in UK
100.This section contains the anti-avoidance rules for earnings from associated employments. They derive from paragraph 2 of Schedule 12 to ICTA.
101.The effect of these rules is to limit the amount of overseas earnings taxed on the remittance basis because of the operation of sections 22 and 23 in cases where there are associated employments. The reference in subsection (3) to “section 23(3)” means that this section adopts the same approach as described in paragraph 95. See Change 3 in Annex 1.
102.Where this section does apply a limit to the amount of general earnings computed under section 23 to be within section 22, any excess of the overseas earnings above that limit falls within section 21. This is set out in subsection (7).