ERSM160845 | Ascertaining Foreign Securities Income (FSI) - up to 5 April 2015: NOR/s26A employees - conditions to be met
From HM Revenue & Customs · Employment Related Securities Manual
An employee who is not ordinarily resident in the UK (from 6 April 2013 is not domiciled in the UK and meets the requirements of section 26A) can have FSI in a tax year if all the following conditions in ITEPA03/S41C(6) are met:
the individual is not ordinarily UK resident in the year (from 6 April 2013, meets the requirements of section 26A) , and
some or all the duties of the employment are performed outside the UK