The following Share Incentives practice note Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch provides comprehensive and up to date legal information covering:
This Practice Note discusses the taxation of internationally mobile employees and directors in relation to employment-related securities (ERS) charged to tax within Part 7 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003). The scope of the charge to income tax is important not only for the individuals themselves (in determining their income tax liabilities) but also for employing companies in determining the associated pay as you earn (PAYE) and National Insurance contributions (NICs) liabilities.
This Practice Note considers only the UK income tax and NICs position. There may also be tax implications in other jurisdictions with which the individual or employing company is connected. These non-UK tax considerations are outside the scope of this Practice Note and local law advice should be taken.
Internationally mobile employees and directors are those individuals who work in different jurisdictions around the world (whether concurrently or consecutively). They include:
UK residents going overseas to work
overseas residents coming to the UK to work, and
UK and overseas residents who move in and out of the UK
This Practice Note considers the jurisdictional scope of the UK income tax charges on ERS.
For details of the PAYE and NICs implications for the employing company, see Practice Notes: PAYE—readily convertible assets, intermediaries and jurisdictional scope—Jurisdictional scope and NICs implications of employment-related securities and securities options.
There are also registration and reporting obligations
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This Practice Note considers the nature and scope of arbitration agreements with a particular focus on arbitration agreements pursuant to the law of England and Wales, although it also discusses the concept from an international perspective and includes some comparative examples from other
The principle of transferred maliceIf a person has a malicious intent towards X and, in carrying out that intent, injures Y, he is guilty of an offence. So, if D shoots at A with intent to kill him but kills B by mistake it is murder; the mistake as to the identity of the victim is irrelevant as D
Criminal offences are generally divided into two categories: •conduct crimes, and •result crimesA conduct crime is a crime where only the forbidden conduct needs to be proved. For example, an accused is guilty of dangerous driving if they drove a motor vehicle dangerously on a road or other public
The principles of the notarial act are that it is:•an act of the notary and not of the parties named in the document•a record of a fact, event or transaction•in the form of a document, notwithstanding the form of the underlying document, fact, event or transactionThe purpose of the notarial act is
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