3

Subsection (4) applies if the value of the relevant step, or a part of it, is “for”—

a

a tax year for which A is non-UK resident, or

b

a tax year that is a split year as respects A.

4

The value, or the part of it, is to be reduced—

a

in a case within subsection (3)(a), by so much of the value, or the part of it, as is not in respect of UK duties, and

b

in a case within subsection (3)(b), by so much of the value, or the part of it, as is both—

i

attributable to the overseas part of the tax year, and

ii

not in respect of UK duties.

5

The extent to which—

a

the value, or the part of it, is not in respect of UK duties, or

b

so much of the value, or the part of it, as is attributable to the overseas part of the tax year is not in respect of UK duties,

is to be determined on a just and reasonable basis.

5A

Any attribution required for the purposes of subsection (4)(b)(i) is to be done on a just and reasonable basis.

5B

“UK duties” means duties performed in the United Kingdom.