In the tax years before 6 April 2015 certain legislation (see ERSM160300) only applied to gains on unapproved share or share options which were acquired when the employee was resident in the UK (and therefore assessable under either ITEPA 2003, ss 15, 22 or 26) at the time that the options were granted.
In addition, all or part of such an option gain could be assessed on a non-resident if it accrued over a period of residence that related to an employment which included UK duties (the earnings for which were assessable under either ITEPA 2003, ss 15 or 27). Furthermore, any part of such a gain that accrued over a period of residence in which the individual was assessable on their non-UK earnings on the remittance basis (under either ITEPA 2003, ss 22 or 26) could also be taxed on the remittance basis.
Pre-6 April 2015 assessment of share-related gains
Where the pre-6 April 2015 rules applied, the gains on exercise of the options were assessable to UK income tax, regardless
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