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United Kingdom
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Overseas Workday Relief before 6 April 2025—German secondee in UK: eligibility, remittance basis, mixed funds, foreign accounts, UK/DE property taxes (IHT, SDLT, CGT), and cross‑border succession

Practice notes
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This Practice Note has been archived and is no longer maintained.

Finance Act 2025 (FA 2025) brings in legislation to abolish the remittance basis of taxation and to replace it with a residence-based regime from 6 April 2025.

Adjustments have also been made to overseas workday relief, so that an employee’s entitlement depends on their residence for the relevant tax year and, subject to certain transitional provisions, whether they are eligible for the four-year foreign income and gains regime for that year.

For details on these updates, see the following Practice Notes:

  • The abolition of the remittance basis of taxation from 2025–26
  • Foreign income and gains regime from 6 April 2025
  • Overseas Workday Relief from 6 April 2025

For the OWR rules that applied before 6 April 2025, see Practice Note: The statutory residence test—overseas workday relief before 6 April 2025 [Archived].

Facts

Petra is a German national and is domiciled in Germany for UK tax purposes. She normally resides in Berlin and is employed full time by a German engineering company, Stein AG, in Berlin...

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Web page updated on 21/05/2026

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