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HMRC internal manual

Employment Related Securities Manual

Securities acquired for less than market value: effect of residence status


From 6 April 2015, with the removal of the residence exclusion at ITEPA03/S474 (see ERSM20300), Chapter 5 will apply to all employment-related securities options, regardless of residence status at the time of the grant of the option, so that Chapter 3C no longer has particular significance in relation to options and residence.

For guidance on the effect of residence on charges under Part 7 generally, including Chapter 3C, from 6 April 2015 onwards, see ERSM162000.

Accordingly, the follow sections explore interactions between residence and the taxing provisions of Chapter 3C for years up to 5 April 2015 only:

Acquisition of securities by exercise of option granted overseas ERSM70410
Employee resident but not ordinarily resident in UK (overseas workdays) ERSM70420
UK duties before permanent arrival in the UK ERSM70425
Non-residents ERSM70440
Non-option LTIPs awarded abroad ERSM70450
Date of departure from UK and split years ERSM70460