For employment income arising in respect of employment-related securities under ITEPA 2003, Part 7 (Employment income: Income and exemptions relating to securities), there have been two principal pieces of legislation that are relevant in an ‘international’ context. The first of these restricts the circumstances in which the Part 7 regime applies at all. But where Part 7 does apply, to give rise to an amount of employment income, the second of these then applies a ‘remittance basis’ approach in relation to such employment income (or to the relevant part of it).

The two provisions are:

(a)ITEPA 2003, s. 421E and, with respect to securities options, s. 474;

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