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HMRC internal manual

Employment Related Securities Manual

The relevant period - up to 5 April 2015: Chapter 3 example

On 1 August 2008 Jessica is awarded loan notes which will convert into ordinary shares if she remains in employment for 3 years. She is R/NOR for 2008/09 and R/OR for subsequent years. She splits her working time between the UK and the USA. She remains in employment and the loan notes convert on 31 July 2011, giving rise to a Chapter 3 chargeable event. Jessica claims the remittance basis under ITA07/S809B for 2008/09.

The relevant period runs from 1 August 2008 to 31 July 2011.