ERSM165210 - International from 6 April 2025: ascertaining chargeable and unchargeable foreign securities income - from 6 April 2025: Introduction
Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
From 6 April 2025, where the Securities Income is apportioned to a tax year in which the employee is eligible for OWR under Chapter 5C of Part 2 ITEPA, this income will no longer be treated as “Foreign Securities Income” under s41H ITEPA and instead will be treated as “Securities Income” under Chapter 5B of Part 2 ITEPA.
The effect of this is that any income that is eligible for OWR under Chapter 5C ITEPA will not be deducted from SI in the SI-FSI calculation at s41F(3) ITEPA.
The employee may then be able to obtain relief on this portion of the income separately through OWR under Chapter 5C ITEPA. Please see EIM43555 onwards.
The calculation of Foreign Securities Income under s41H ITEPA, for any part of the relevant period before 6 April 2025 is unchanged, with the remittance basis rules continuing to apply.