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HMRC internal manual

Employment Related Securities Manual

International from 6 April 2015: ascertaining chargeable and unchargeable foreign securities income - from 6 April 2015: not s26A employees

ITEPA03/S41H(3) says that if any part of the relevant period is within a tax year to which subsection (4) applies (ERSM162625), the securities income treated as accruing in that part of the period is “foreign”. This is subject to ITEPA03/S41I, which applies where the employee has one or more associated employments with UK duties - see ERSM160830.

It is also subject to ITEPA03/S24A (Restrictions on remittance basis), on which guidance can be found at []