Taxation of Chargeable Gains Act 1992 section 119B

Section 119A: unchargeable, and unremitted chargeable, foreign securities income

Section 119B reduces the uplift to acquisition cost under section 119A for employment-related securities where the employment income includes foreign securities income that is either unchargeable or has not been remitted to the UK, and provides a mechanism for later adjustment if that income is subsequently remitted.

• When calculating the section 119A uplift to acquisition cost, any employment income that is unchargeable foreign securities income or unremitted chargeable foreign securities income must be excluded from the amount that increases the base cost.
• Unchargeable foreign securities income is income that falls outside the UK tax charge for internationally mobile employees, while unremitted chargeable foreign securities income is income that is within the UK tax charge but has not been brought into the UK by the end of the tax year in which the disposal takes place.
• If any of the previously unremitted chargeable foreign securities income is later remitted to the UK after the tax year of disposal, the taxpayer may make a claim to have the section 119A uplift recalculated as though that income had been remitted before the end of the disposal year.
• Any necessary adjustments arising from such a claim — whether by way of tax repayment, assessment, or otherwise — may be made at any time, overriding normal statutory time limits for capital gains tax.