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Section 41U ITEPA 2003 defines what it means for third party income to be “qualifying third party incomeâ€� and for qualifying third party income to be “qualifying foreign third party ¾±²Ô³¦´Ç³¾±ðâ€�.Ìý

“Third party incomeâ€� is an amount that counts as employment income under Chapter 2 of Part 7A ITEPA 2003 (see EIM45000+).Ìý

Third party income is “qualifying third party incomeâ€� to the extent that the value of the relevant step that counts as employment income is “forâ€� the qualifying year (see EIM45720) and it is in respect of an employment the duties of which are performed wholly or partly outside the UK during the qualifying year.Ìý

If the qualifying year is a split year, only the third party income attributable to the UK part of the year can be qualifying third party income. Any attribution required is to be done on a just and reasonable basis.Ìý

Qualifying third party income is “qualifying foreign third party incomeâ€� to the extent that it is not in respect of duties performed in the UK. The extent to which qualifying third party income is not in respect of duties performed in the UK is to be determined on a just and reasonable basis.Ìý