Time apportionment: securities options

The effect of a double taxation treaty was discussed at ERSM161310. If the UK is not the country of residence when a chargeable event happens, then the employee may be resident in a territory with which we have a double taxation treaty. If so, they will be able to make a claim that the UK restricts its liability to the amount derived from employment in the UK. This is commonly referred to as ‘time apportionment’.

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