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HMRC internal manual

Employment Related Securities Manual

International from 6 April 2015: the relevant period - from 6 April 2015: chapter 3 example

On 1 August 2013 Jessica is awarded loan notes which will convert into ordinary shares if she remains in employment for 3 years. She is resident but not domiciled in the UK and meets the requirements of ITEPA03/S26A (see ERSM162615) for 2013/14 and resident but not domiciled in the UK and does not meet the requirements of ITEPA03/S26A for subsequent years. She splits her working time between the UK and the USA. She remains in employment and the loan notes convert on 31 July 2016, giving rise to a Chapter 3 chargeable event. Jessica claims the remittance basis under ITA07/S809B for 2013/14.

The relevant period runs from 1 August 2013 to 31 July 2016.