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Share schemes residence issues—overview and history

The current regime for taxation of shares and share options dates from 2015/16 onwards. However there were a number of changes in the preceding years. Some information on these earlier rules may be found at E4.508DA. These historical changes can be summarised briefly as follows:

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   •ÌýÌýÌýÌý prior to 2015/16, whether or not UK tax was due largely depended on the employee's residence and ordinary residence status at the time the shares or share options were awarded. This had the consequence that, for example where an employee became UK resident after a share option was first awarded, and the share option was not granted in anticipation of UK employment, no UK liability arose. Also, trailing liabilities could arise after leaving the UK if the option etc was first awarded whilst UK resident (subject to claims for double taxation relief or treaty exemption). By contrast, current rules now concentrate more simply on the period over which the share or share option income has been earned or accrued over (see 'relevant accrual period'