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HMRC internal manual

Employment Related Securities Manual

Remittance of foreign securities income and the interaction with capital gains - up to 5 April 2015: TCGA92/S119B

TCGA92/S119B was introduced by Schedule 7 of Finance Act 2008 and applies to employment-related securities (ERS) acquired on or after 6 April 2008. Its effect is to reduce the amounts which are treated by section 119A as forming part of the acquisition cost of the ERS where there is a disposal of the same asset for CGT purposes. It does this in two ways:

  • firstly, by reducing the amount which counts as employment income under the provisions referred to in section 119A(3), and which would otherwise form part of that acquisition cost, by the amount of any “unremitted foreign securities income”;
  • secondly, by providing for further adjustments to the CGT position where any of the “unremitted foreign securities income” is remitted after the year of disposal.