ERSM160850 - Ascertaining FSI: NOR employees - duties wholly outside the UK

Where in a tax year:

• the conditions in ITEPA03/S41C(6) are all met;
• the duties of the NOR individual’s employment are performed wholly outside the UK, and
• the relevant period falls wholly or partly within that year

then any securities income accruing during that part of the relevant period is treated as FSI, and is therefore only taxable if remitted to the UK.