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HMRC internal manual

National Insurance Manual

Class 1 NICs: Employment Related Securities (ERS): Internationally Mobile Employees (IMEs): the Double Charge

The treatment of IMEs earnings from ERS introduced in the UK by Paragraph 18 of Part 9 of Schedule 3 Social Security (Contributions) Regulations (SSCR) 2001 is not a co-ordinated practice that is followed by all other countries.

Where a ‘double charge’ has occurred resulting in both the UK and another country requiring social security contributions from the ERS earnings for the same period/amount in which there is a UK NICs liability, please write to:

HM Revenue & Customs
International Caseworker
Benton Park View
Newcastle upon Tyne
NE98 1ZZ

You should provide full disclosure of the facts.

N.B. This only applies to EEA states and RA/DCC countries, see NIM06905 and NIM06910.