Deferred remuneration

We act for a non-domiciled individual who came to the UK in 1991 and took up full-time employment with the UK subsidiary of a multi-national company whose holding company is resident in Switzerland.
Our client worked for the UK company and received large salaries until he retired in December 2003. He subsequently had a small self-employment from January to July 2004 when he left the UK and he now resides abroad. Our client was entitled to deferred remuneration in respect of the period when he was employed by the UK company and this amounting to £150 000 is payable in quarterly instalments over a five-year period following his leaving the company.
The payments have been made by the Swiss holding company direct to our client overseas yet the UK subsidiary has issued forms P60 showing the gross amount of the instalments paid with no...