Where the employee is partly within the UK tax net before becoming resident in the UK, by performing UK duties, then part of the gain relating to the non-UK work before arrival may be excluded from the computation.
Hannah Matthews is resident and employed in the USA and is
granted a legal option over shares with a three year vesting
period. In each of years 1 and 2 she spends 3 months working in the
UK and for year 3 moves to the UK to work here full-time. She
exercises her option at the end of year 3 making a gain of
£5,000.
The gain of £5,000 will create a notional loan, but the
loan will be reduced by the non-UK working periods:
| Gain | £5,000 |
| Year 1 9/12 of one third | (£1,250) |
| Year 2 9/12 of one third | (£1,250) |
| Notional loan | £2,500 |
