ERSM161220 - Remittance of FSI and
the interaction with capital gains: TCGA92/S119B
TCGA92/S119B was introduced by Schedule 7 of Finance Act 2008
and applies to employment-related securities (ERS) acquired on or
after 6 April 2008. Its effect is to reduce the amounts which are
treated by section 119A as forming part of the acquisition cost of
the ERS where there is a disposal of the same asset for CGT
purposes. It does this in two ways:
- firstly, by reducing the amount which
counts as employment income under the provisions referred to in
section 119A(3), and which would otherwise form part of that
acquisition cost, by the amount of any “unremitted foreign
securities income”;
- secondly, by providing for further
adjustments to the CGT position where any of the “unremitted
foreign securities income” is remitted after the year of
disposal.
