Income Tax (Earnings and Pensions) Act 2003 section 41G

Section 41F: the relevant period

Section 41G defines the "relevant period" used to apportion employment-related securities income between UK-taxable and non-UK-taxable amounts for internationally mobile employees.

  • The relevant period varies depending on the type of security or option involved, generally running from acquisition to the chargeable event or option vesting date
  • For some charges (such as artificially depressed or enhanced market value securities, disposals above market value, and post-acquisition benefits), the relevant period is based on the tax year in which the triggering event occurs
  • Where securities were acquired for less than market value via a securities option, the period runs from the day the option was acquired to the day it vests
  • If the standard rules produce a result that is not just and reasonable in all the circumstances, a just and reasonable period may be substituted instead

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