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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

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HM Revenue & Customs
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Schedule 3 SAYE option schemes: Requirements relating to share options: Exercise rights: Participants becoming US taxpayers

Difficulties may arise for Schedule 3 SAYE option holders if during the life of an option they are transferred to work in the U.S.A. and become subject to US Tax. It is therefore acceptable for plans to contain a role applicable to US taxpayers, which only allows US taxpayers to exercise within the period permitted by the short terms deferral exemption from section 409A of the US Internal Revenue Code.