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HMRC internal manual

Employment Related Securities Manual

Ascertaining Foreign Securities Income (FSI) - up to 5 April 2015: NOR/s26A employees - conditions to be met

An employee who is not ordinarily resident in the UK (from 6 April 2013 is not domiciled in the UK and meets the requirements of section 26A) can have FSI in a tax year if all the following conditions in ITEPA03/S41C(6) are met:

  • section 809B, 809D or 809E of ITA 2007 applies to the individual for the year;
  • the individual is not ordinarily UK resident in the year (from 6 April 2013, meets the requirements of section 26A) , and
  • some or all the duties of the employment are performed outside the UK