International: introduction to Internationally-Mobile Employee (IME) matters
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; and
- explain the changes to the residence rules for employment-related securities introduced by Finance Act 2014, having effect from 6 April 2015.
Guidance for periods up to 5 April 2015
ERSM160200 to ERSM161400 deal with the treatment of employment-related securities and residence up to 5 April 2015. The impact of the FA2008 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.
Guidance for periods from 6 April 2015
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 and ERSM163110).