ERSM165215 - International from 6 April 2025: ascertaining chargeable and unchargeable foreign securities income - from 6 April 2025: Not s26A employees
s41H, Chapter 5B of Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA)
s41H(3) Chapter 5B ITEPA 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 s41I ITEPA, which applies where the employee has one or more associated employments with UK duties.
For any part of the relevant period on or after 6 April 2025, income apportioned to any part of the relevant period in which the employee would previously have met the requirements of s41H(4) ITEPA will no longer be considered Foreign Securities Income.
Therefore, the income will not be deducted from the Securities Income in the calculation at s41F(3) ITEPA and instead will be considered Securities Income.
Please see the example at ERSM165238.