Introduction

This Practice Note discusses the taxation of internationally mobile employees and directors in relation to employment-related securities (ERS) and employment-related securities options charged to tax within Part 7 of the Income Tax (earnings and Pensions) Act 2003 (ITEPA 2003). The scope of the charge to income tax is important not only for the individuals themselves (in determining their income tax liabilities) but also for employing companies in determining the associated pay as you earn (PAYE) and National Insurance contributions (NICs) liabilities.

This Practice Note considers only the UK income tax and NICs position. There may also be tax implications in other jurisdictions with which the individual or employing company is connected. These non-UK tax considerations are outside the scope of this Practice Note and local law advice should be taken.

Internationally mobile employees and directors are those individuals who work in different jurisdictions around the world (whether concurrently or consecutively). They include:

1. •

   UK residents going overseas to work

2. •

   overseas residents coming to the UK