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

VAT on property disposals

VAT on property disposalsThis guidance note provides an overview of the VAT treatment of selling property that is located in the UK. The UK includes Great Britain, Northern Ireland and the territorial sea of the UK. The sale of any land or building located outside the UK is outside the scope of UK

14 Jul 2020 13:57 | Produced by Tolley Read more Read more

Carried-forward losses restriction

Carried-forward losses restrictionOverview of the carried-forward loss restrictionAn important restriction in the use of losses carried forward was introduced by Finance (No 2) Act 2017. Subject to a de minimis of £5m (known as the deductions allowance), most carried-forward losses are restricted to

14 Jul 2020 11:09 | Produced by Tolley Read more Read more

Double tax relief

Double tax reliefWhen income arises in a foreign country to a UK resident company and that income is taxable in that foreign country, the UK may give the company relief for the foreign tax by crediting the foreign tax against the UK tax charged on that income. This might include withholding tax on

14 Jul 2020 11:31 | Produced by Tolley Read more Read more