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HMRC internal manual

Employment Related Securities Manual

HM Revenue & Customs
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International from 6 April 2015: ascertaining chargeable and unchargeable foreign securities income - from 6 April 2015: introduction

The concept of “foreign securities income” is introduced by ITEPA03/S41F(4). Section 41F(4)(b) says that foreign securities income (“FSI”) is the amount of securities income that is foreign. Subsection (5) says that FSI consists of any chargeable foreign securities income and any unchargeable foreign securities income. Those amounts are determined according to the rules in ITEPA03/S41H to ITEPA03/S41L. Unchargeable foreign securities income is not charged to tax as employment income. Chargeable foreign securities income is only taxed if it is remitted to the UK (ITEPA03/S41F(6)).