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Employment-related securities: internationally mobile employees


Produced by Tolley in association with
Employment Tax
Guidance
tag-icon Brexit

Employment-related securities: internationally mobile employees


Produced by Tolley in association with
Employment Tax
Guidance
tag-icon Brexit
imgtext

STOP PRESS: The remittance basis is 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. The legislation is included in FA 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

General principles

Where a UK resident employee acquires or is granted the right to acquire employment-related securities (ERS), the employee is subject to certain UK tax and regulatory requirements which apply no matter where the issuer of those ERS or the employer is located.

For tax, the basic principle is that the employee is charged to income tax on the value received. The situation becomes more complex where that employee is internationally mobile and the relevant rules are outlined below.

Where an event occurs in connection with the acquisition, holding or disposal of ERS, and is chargeable to UK income tax, there is a requirement

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Caroline Harwood
Caroline Harwood

Partner, National Head of Employment Tax at BDO , Employment Tax

Caroline leads the Employment Tax Team in London and has over 25 years’ experience specialising in all aspects of employment taxes. Her clients range from entrepreneurial fast growing businesses to international household names as well as charities and not for profit organisations.Her focus is across all aspects of employment taxes in particular the off-payroll working rules (IR35), employment status for tax, termination/settlement payments, employment tax implications of agile working arrangements, management team advice on transactions, employee benefit reviews, PAYE/NIC compliance and reporting etc.

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  • 20 Mar 2025 15:53

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