Postby petergibbinson » Wed Feb 02, 2011 5:42 am
This is very complicated but if your client was awarded the shares when in the UK and they vested when non resident/NOR then yes UK tax is due and it is treated as if it is Uk income and goes on the share schemes box in the tax return.
As a corollary any shares awarded when non resident/NOR are not liable to UK tax when they return to the UK (even if they vest when back in the UK)..but the tax rules of the jursustiction they were awarded in apply (so awarded in Dubai no tax, awarded in Singapore whatever the marginal rate of tax is) SIngapore actually make you pay the tax due when you leave the country even if they havent vested yet (based on the share price on leaving Singapore), and if for some reason they dont vest or you make a loss compared to that exercise price you need to claim that back.
It amazes me corporations dont make this clearer to employees to make this all easier.