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  • RE: Split year treatment

    Hi, I left the UK in which split year rules applied. I remained in the same corporate group, but my employment contract is terminated by the UK entity along with my payroll. The very next day, I am employed by the overseas entity and put onto the overseas entity payroll. A few months afterwards, I received a cash bonus paid to me by the overseas entity and I am withheld tax as I am on the overseas payroll. Do I need to do anything about this in the UK at all if it is paid by the overseas entity into my overseas bank account where I live and with overseas tax withheld under the overseas payroll?
  • LTIP exercises after moving overseas

    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?