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HMRC internal manual

Employment Related Securities Manual

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HM Revenue & Customs
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Ascertaining Foreign Securities Income (FSI) - up to 5 April 2015: examples: example 3 - NOR employee with overseas duties

In 2009/10 Tom is resident and domiciled in the UK, but not ordinarily resident. Whilst he is resident in the UK, he works entirely overseas for an Italian employer. On 1 July 2009 he is awarded a share option which he exercises on the day that it vests, 31 March 2010, realising a gain. He claims the remittance basis of taxation under ITA07/S809B for the year.

All the conditions in ITEPA03/S41C(6) are met for 2009/10.

The relevant period for the share option (01/07/09 to 31/03/10) falls wholly within 2009/10.

As the duties of the Italian employment are performed wholly outside the UK, the whole of the share option gain is treated as FSI and will be taxed only if remitted to the UK.

For the application of this and the other examples to periods from 6 April 2013, see ERSM160873.