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HMRC internal manual

Employment Related Securities Manual

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HM Revenue & Customs
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International from 6 April 2015: principles of the Finance Act 2014 residence rules for employment-related securities & options

With the removal of ITEPA03/Ss421E and 474(1) by Finance Act 2014 from 6 April 2015, the provisions of Part 7 ITEPA now apply universally.

As a result, there are no territorial limits to the application of Part 7. Instead, from 6 April 2015, if an amount counts as employment income under Chapters 2 to 5 of Part 7 (‘securities income’) of an ‘internationally mobile employee’, new Chapter 5B of Part 2 of ITEPA 2003 determines the amount of the securities income which is taxable in the UK.

Broadly, Chapter 5B is intended to establish the period to which securities income can be regarded as relating and to apply to that income an approach similar to that provided by Chapters 4 and 5 of Part 2 in relation to general earnings. (See EIM40000 onwards.)

Commencement

The new rules of Chapter 5B, Part 2 of ITEPA 2003 apply to employment-related securities options and employment-related securities from 6 April 2015, regardless of when they have been acquired.