Changes to employment related securities and security options


HMRC has introduced important changes to the UK tax treatment of unapproved employment related share income, such as stock options.

This will not only impact expatriates but also employees who have spent some time working internationally (foreign employees who are/have worked in the UK or UK employees who are/have worked overseas). These changes apply from 6 April 2015.

There will be some winners, including those who leave the UK to work in non-treaty countries, such as the Middle East, who will now be taxed on an apportioned basis, whereas previously options would have been subject to tax in full. However, there will be some practical difficulties and in some situations the UK taxes due will now increase, particularly for those that were previously not resident at grant and not subject to UK tax.

For more information, please contact your usual Blick Rothenberg contact or Mark Abbs, partner on +44 (0)20 7544 8744 or at