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HMRC internal manual

Employment Related Securities Manual

HM Revenue & Customs
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Ascertaining Foreign Securities Income (FSI) - up to 5 April 2015: non-domiciled/not s26A employees

ITEPA03/S41C(3) says that if any part of the relevant period is within a tax year to which subsection (4) applies, the securities income treated as accruing in that part of the period is “foreign”. This is subject to ITEPA03/S41D, which applies where the non-domiciled employee has one or more associated employments with UK duties - see ERSM160830.

With effect from 17 July 2014 it is also subject to ITEPA03/S24A (Restrictions on remittance basis), on which guidance can be found at