Employment-related securities and the remittance basis

Produced by Tolley in association with

Employment Tax

Guidance

STOP PRESS: At Spring Budget 2024, the Chancellor announced that the remittance basis would be abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

Introduction

The current rules relating to the UK tax treatment of employment related securities where internationally mobile employees are involved came into force on 5 April 2015. Tax liability is calculated by reference to where the employee is resident and working during the vesting period. This effectively aligns UK tax treatment with international practice as well as equalising the position for UK employees and internationally mobile employees working in the UK.

This guidance note looks at how the rules on taxation of employment-related securities, the remittance basis and using mixed funds all interact.

UK tax liability in connection with employment related securities

The

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Karen Speight

Freelance Lecturer

Qualified as both a solicitor and a Chartered Tax Advisor, Karen has over 25 years' experience in professional services, including 11 years as a partner at Ernst & Young. Whilst in practice, she specialised in all aspects of employee reward and development including design, implementation, compliance and administration, and now enjoys using that experience to help develop others.

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