Chapter EIM40009

Published date22 May 2014
Record NumberEIM40009
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

In 2007 and 2008, HMRC consulted with professional advisers with particular expertise regarding the treatment of foreign nationals coming to work in the UK and UK residents leaving the UK to work abroad. Many of the advisers’ clients have complex remuneration packages. Some are members of Long Term Incentive Plans or participants in other deferred remuneration schemes. The aim of the exercise was to establish principles for determining the tax year that earnings, delivered by these arrangements, are “for”.

The guidelines set out on the following pages were adopted by HMRC with effect from 28 February 2008. They are intended to be comprehensive but do not claim to cover every plan and set of circumstances that will arise.

EIM40011 Approach to determining the year that earnings are “for”
EIM40012 Annual bonuses awarded for meeting corporate, team or personal targets
EIM40013 Bonuses and deferred remuneration plans – the effect of conditionality and employer’s discretion
EIM40014 Long Term Incentive Plans and Deferred Remuneration
EIM40015 The year that awards from Long Term Incentive Plans and other deferred remuneration arrangements are “for”
EIM40016 Staged vesting

The guidance sets out general principles and indicates the views HMRC is likely to take in specified circumstances. It is intended to aid and inform fact finding and decision making. It is not a substitute for obtaining all of the relevant information and exercising good judgment by applying the principles to the...

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