ERSM160100 - International

Introduction

This chapter does not attempt to reproduce material that is found in other manuals or information sources. Instead its purpose is to

• summarise how domestic rules, treaties, etc fit together;
• explain the remittance rules for employment-related securities introduced by Finance Act 2008.

More guidance will be produced over the coming months regarding various aspects of the new rules introduced by Finance Act 2008. In particular, it is envisaged that extra examples will be added to illustrate the working of the rules in less straightforward circumstances

The impact of the new residence and domicile rules is summarised in ERSM160300 and the following sections explain how employment-related securities are taxed in the hands of employees to whom the remittance basis applies; the effect of double taxation treaties is outlined at ERSM161300

Internationally mobile employees (IMEs)

This general term is used to describe:

• UK residents going overseas to work;
• overseas residents coming to the UK to work; and
• UK or overseas residents who move in and out of the UK.

Thus, it does not define any particular residence status or tax treatment and you should always ascertain the specific facts and status relating to an employee before reaching any conclusion on the tax treatment of his or her employment-related securities and options (see ERSM161310).