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Posted Sat, 10 Sep 2022 18:02:15 GMT by P K
Hi, I am moving from the UK to Greece (double taxation agreement in place), I will continue working for the same company on the equivalent Greek entity. The employer have granted me RSUs in the past which they vest over the course of the next 2 years. Since I will no longer be a UK tax resident, am I liable to UK tax on all the future vestings or not? There are contradicting points in the web, on one post in this forum HMRC representative claims that you pay tax at vest in UK if you are UK tax resident at that time otherwise you have to pay in the new country. On the other hand others claim that you pay a portion of the UK tax for the days you spend in the UK between grant and vest and the rest goes to the new country. Thanks
Posted Tue, 13 Sep 2022 16:50:18 GMT by HMRC Admin 10
You would be liable to tax in the country you are resident in, at the time the RSU's are vested.
Posted Tue, 13 Sep 2022 18:25:52 GMT by P K
Thanks for the response HMRC this is quite different to what my company is making me pay taxes for. What they say is better explained with an example... Let's say that * I was granted 100 RSUs on 6/4/22 * I moved out of the UK on 6/7/22 (3 months after grant) and I immediately stop being a UK tax resident * Vest date is on 6/4/23 (12 months after grant, new economic year) which at that point the stock price is 1k£, so overall value is 100k£ What my company (publicly listed in a US exchange) says is that I will be taxed in the UK from the day of the grant to the day that I left the UK. So on the above example they calculate... * number of days between grand and vest = 366 (1 year) * number of days I spent in the UK between grant and vest = 91 (since I moved out 3 months after the grant) * they calculate a ration 91/366=24.8% * and they calculate that I am liable to pay UK tax for 100k£*24.8%=24.8k£ I'd appreciate if you can point me to any HMRC documentation supporting the above calculations. Thanks
Posted Wed, 14 Sep 2022 16:34:30 GMT by HMRC Admin 10
We are unable to comment on hypothetical situations.
Posted Wed, 14 Sep 2022 16:47:59 GMT by P K
This is not hypothetical, this is the scenario I am facing with obfuscated numbers and dates as this is a public forum.
Posted Mon, 30 Jan 2023 12:42:42 GMT by P K
After much digging I figured that HMRC's response is incorrect in my question and that my original statement is truthful. For anyone that might be looking into this you can more information here

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