Paragraph 10

After that section insert—

“Section 26: requirement for 3-year period of non-residence

26A

(1)

An employee meets the requirement of this section for a tax year if the employee was—

(a)

non-UK resident for the previous 3 tax years, or

(b)

UK resident for the previous tax year but non-UK resident for the 3 tax years before that, or

(c)

UK resident for the previous 2 tax years but non-UK resident for the 3 tax years before that, or

(d)

non-UK resident for the previous tax year, UK resident for the tax year before that and non-UK resident for the 3 tax years before that.

(2)

The residence status of the employee before the 3 years of non-UK residence is not relevant for these purposes.”