ÀÏ˾»úÎçÒ¹¸£Àû

Employment-related securities: internationally mobile employees

Produced by Tolley in association with
Employment Tax
Guidance

Employment-related securities: internationally mobile employees

Produced by Tolley in association with
Employment Tax
Guidance
imgtext

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 to report details to HMRC. HMRC can require any ‘responsible person’ (as defined in ITEPA 2003, s 421L(3)) to report. Broadly a responsible person may be the employer, the host employer, or the issuer of the securities (special provisions apply to continental shelf workers). In practice, typically the employer or issuer of the securities (eg the holding company of a group) will make the report.

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+â„¢
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.

Powered by
  • 12 Jun 2025 10:10

Popular Articles

Spouse exemption from inheritance tax

Spouse exemption from inheritance taxArguably, the most important inheritance tax exemption is the spouse exemption from inheritance tax.There is no IHT to pay on gifts from husband to wife and vice versa, or from one civil partner to the other (referred to collectively in this note as ‘spouses’).

14 Jul 2020 13:56 | Produced by Tolley in association with Emma Haley at Boodle Hatfield LLP Read more Read more

FRS 102 ― tax presentation and disclosures

FRS 102 ― tax presentation and disclosuresPresentation of tax under FRS 102An entity must present changes in a current tax liability (or asset) and changes in a deferred tax liability (or asset) as a tax expense (or income) unless the item creating the current or deferred tax amount is recognised in

14 Jul 2020 11:46 | Produced by Tolley in association with Malcolm Greenbaum Read more Read more

Fuel-related payments / mileage payments

Fuel-related payments / mileage paymentsIntroductionMost employers will make payments to employees in relation to business travel. Among the most common payments in relation to business travel are fuel and mileage payments. If an employer does not reimburse these amounts, then the employee will be

14 Jul 2020 11:46 | Produced by Tolley in association with Philip Rutherford Read more Read more