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Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Internationally mobile employees content

Practice notes
Given the ever increasing global mobility of employees, employers could be regularly required to understand and comply with numerous legislative...
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Produced in partnership with Darren Oswick of Simmons & Simmons 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch 9th Apr
Practice notes
This Practice Note summarises the taxation of internationally mobile employees and directors in relation to securities options (Options) charged to...
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Produced in partnership with Lewin Higgins-Green of FTI Consulting 9th Apr
Practice notes
IntroductionThis Practice Note discusses the taxation of internationally mobile employees and directors in relation to securities options (options)...
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Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch 9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.Following recommendations of the Office of Tax Simplification and an HMRC...
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9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.One of the features of the UK employment income tax rules has long been to afford...
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Produced in partnership with Darren Oswick of Simmons & Simmons 9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.Following recommendations of the Office of Tax Simplification and an HMRC...
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9th Apr
Practice notes
Overseas Workday Relief (OWR) is a relief from UK income tax for certain non-domiciled individuals, who have elected to be taxed on the remittance...
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Produced in partnership with Lisa Spearman of Mercer & Hole 9th Apr
Practice notes
The UK’s first formal tax residency test for individuals known as the statutory residence test (SRT) took effect on 6 April 2013. Before this, whether...
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Produced in partnership with Lisa Spearman of Mercer and Hole and Emma Loveday of Wedlake Bell LLP 9th Apr
Q&As
As a result of measures to slow down the spread of coronavirus (COVID-19), many countries including the UK are in lockdown. For employees, this often...
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Produced in partnership with Laura Allwright of Simmons & Simmons and Darren Oswick of Simmons & Simmons 15th Feb
Q&As
Before introducing a non-UK tax resident individual as a director of a UK company, the company should obtain advice from UK and non-UK tax advisers to...
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29th Nov

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