"Non Dom" Reforms – Impact On Employee Share Plans

The provisions of the Finance Bill 2008 will, if enacted, make significant changes to the way in which employees who are resident but not ordinarily resident in the UK will be taxed in the UK. The changes include the introduction of an alternative basis of charge for tax purposes – the "remittance basis": This briefing reports on the impact of the changes in the context of employee share plans.

Employee Share Options

Employees who are not both resident and ordinarily resident in the UK on the date of grant of employee share options are not currently taxed on the same basis as employees who are both resident and ordinarily resident in the UK at that time in respect of those employee share options.