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)Ìý

From 6 April 2025, where the Securities Income is apportioned to a tax year in which the employee is eligible for OWR under Chapter 5CÌýof Part 2 ITEPA, this income will no longer be treated as “Foreign Securities Incomeâ€� under s41H ITEPA and instead will be treated as “Securities Incomeâ€� under Chapter 5B of Part 2 ITEPA. Ìý

»Ê¹ÚÌåÓýapp 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.ÌýÌý

»Ê¹ÚÌåÓýapp 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.ÌýÌý

»Ê¹ÚÌåÓýapp 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.â€�Ìý