Skip to main content

This is a new service – your feedback will help us to improve it.

Posted Tue, 09 Apr 2024 08:32:19 GMT by UK expat
Hi, I was awarded LTIP during my employment in the UK. It is designed to reward staff should there be an exit event. They had zero value at the time because there is zero liquidity, and no event had happened that allowed their exercising. After moving overseas (with the same employer group but overseas subsidiary), there is an event which allowed the LTIP to be exercised and therefore value to be realised. The LTIP lapses and has zero value if I were to leave employment. Rather than the LTIP value being "for" the years in which I was still a UK tax resident, is it reasonable to take the position that the LTIPs is in fact to retain me in employment (given zero value before and zero if I left) and to reward an exit or liquidity event, that they are therefore taxed overseas as I am non resident in the tax year in which the liquidity event occurs and therefore not subject to UK tax?

You must be signed in to post in this forum.