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HMRC internal manual

Employment Related Securities Manual

International from 6 April 2015: the relevant period - from 6 April 2015: the just and reasonable relevant period

A feature of the previous rules in Chapter 5A is that they can only apply if the remittance basis applies to the individual in any part of the statutory relevant period (see ERSM160910). This means that, for periods up to 5 April 2015, if the remittance basis does not apply to an individual in any part of the relevant period in respect of an amount of securities income, despite the fact that, on a ‘just and reasonable’ view, that income has really been earned over a period in which the remittance basis did apply to the individual, that individual could nevertheless not have the remittance basis in relation to any part of that income.

In contrast with the Chapter 5A relevant period rules at ITEPA03/S41B, the rules for Chapter 5B contain a provision at ITEPA03/S41G(9) which allows the relevant period to be determined on a just and reasonable basis, so that the application of the international mobility conditions (see ERSM162400) can be tested in respect of the right relevant period.