Readers’ forum: Tax treatment of UK- resident’s growth shares

Our client was employed by company A in Hong Kong in 2011. Company A has its headquarters in the UK and has a branch office in Hong Kong. A offered growth shares in 2012 when our client was non-resident in the UK but resident in Hong Kong. The growth shares which have not been used are still available but our client left the company in 2014. Our client is now UK resident. Company A is looking to list in the US stock exchange. Our client has been offered two options by the company: to take cash now to redeem the amount of growth shares; or new shares will be offered once the company is listed in replacement of the old shares with the same conditions attached.

It has been informally advised that option A will be treated as a taxable dividend if our client is UK-resident. However ...