[ERSM161320] ERSM161320 – Interaction of UK law and treaties – up to 5 April 2015: time apportionment
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’.