Her Majesty's Revenue and Customs (HM Revenue and Customs or HMRC) is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of state support and the administration of other regulatory regimes including the national minimum wage.... More are set to make a small but important change to the taxation of share options awarded to internationally mobile employees with effect from 6 April 2015.
If you will not hold any share options at 6 April 2015, or you have never been awarded share options whilst non-UK tax resident, then you will not be affected and you need not read any further.
However, if you have been granted options under an employer share option plan while non-UK tax resident, then you should pay attention to a forthcoming change in this regard. At present, exercising options awarded while non-UK tax resident is unlikely to give rise to a UK tax charge, even if they are exercised whilst UK resident. This is the result of a specific piece of legislation which typically makes option gains non-taxable in this situation.
However, this will change with effect from 6 April 2015 under new legislation put forward in Finance Bill 2014. A UK income charge of some sort is then likely to apply on exercise of these options.
Exercising options which may be affected by the charge before 6 April 2015 could therefore be favourable from a UK tax perspective, and we would be happy to review your circumstances with this in mind.
If you are in possession of options granted whilst non-UK resident, please contact us to discuss what action (if any) might be appropriate.