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FA 2013 introduced legislation from 6 April 2013¹ to replace the previous non-statutory remittance treatment for remittances from mixed earnings foreign bank accounts (known as 'qualifying accounts'). The legislation for these qualifying accounts applies to earnings for the tax years 2013/14 onwards (ie earned after 5 April 2013) and to transfers from a mixed fund of such earnings that are made on or after 6 April 2013². This are known as the 'special mixed fund rules'.

The special mixed fund rules only apply to an employee who is entitled to overseas workday relief (also known as OWR, see E4.1317), which means that the employee has both ITEPA 2003, s 15 arising basis general earnings for UK duties and ITEPA 2003, s 26 remittance basis foreign earnings for non-UK duties³.

An individual with both UK and non-UK earnings cannot have a qualifying account for a tax year throughout which they are non-resident (because the earnings of a non-resident for non-UK duties are not taxable in the UK). However, where a qualifying account