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Internationally mobile employees

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The Finance Act 2014, Schedule 9 (Employment-related Securities etc.) (Consequential etc. Amendments) Regulations, SI 2015/360, will close a potential loophole in the FA 2014 legislation introduced to align the treatment of employment-related securities for both internationally mobile and UK-resident employees with effect from 5 April 2015. The current provision, which deems employee and employer to have elected to pay income tax on the unrestricted value of such securities acquired as part of tax avoidance arrangements, would not apply where an individual acquired the securities in a previous tax year while not UK-resident. These regulations ensure that the deemed election will only apply to securities within the scope of UK earnings at the time of acquisition.
 

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