‘realisation year’, in relation to a person, means-

 

(a)     where that person is a covered person, the year of assessment of that person immediately preceding the year of assessment ending on or after 1 January 2014; or

 

(b)     where that person becomes a covered person during any year of assessment ending after 1 January 2014, the year of assessment of that person that precedes the first year of assessment of that person in which that person becomes a covered person;