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09 June 2005
Issue: 4011 / Categories: Comment & Analysis , Employees , Income Tax

In a special edition of the Tax Bulletin, HMRC explain the NI treatment of internationally mobile employees receiving securities by reason of employment.

TWO MAIN SCENARIOS involve securities options:

In a special edition of the Tax Bulletin HMRC explain the NI treatment of internationally mobile employees receiving securities by reason of employment.

TWO MAIN SCENARIOS involve securities options:

  • Employee resident and ordinarily resident for tax purposes when the securities option acquired: Social Security Contributions and Benefits Act 1992 s 4(4)(a) under which a Class 1 National Insurance liability is 'triggered' by there being an amount that counts as employment income under ITEPA 2003 Part 7 Chapter 5.
  • Employee resident but not ordinarily resident for tax purposes when the securities option acquired: National Insurance liability can be triggered by there being an amount chargeable to tax under ITEPA 2003 Part 7 Chapter 3C.

Where an employee is resident but not ordinarily resident in the UK for tax purposes when the securities option was acquired rather than a charge under ITEPA 2003 s 476 ...

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