Introduction and context This Practice Note summarises the taxation of internationally mobile employees in relation to securities options (Options) charged to tax within Chapter 5 of Part 7 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003). On 30 October 2024, as part of Autumn Budget 2024, the Labour government confirmed that it would proceed with plans of the former Conservative government to abolish the remittance basis of taxation and replace it with a residence-based regime, to commence on 6 April 2025. These changes were enacted as part of Finance Act 2025 (FA 2025) and have also affected the availability and operation of overseas workday relief. This Practice Note reflects the position under the new regime, but the previous regime is still relevant in respect of Options that were granted before 6 April 2025, as any parts of the Options’ ‘relevant period’ (see discussion below, but broadly the vesting period) before 6 April 2025 are still subject to certain aspects of the previous rules. For