A GBP1.237-million payment made to an employee under his employer’s long-term incentive plan was taxable as employment income even though it was paid after he had permanently left both the company and the UK, the Upper Tax Tribunal has ruled. It found that it did not matter that the employment was not held when the payment was received, as the relevant taxable receipt was the payment received and not the grant of the stock appreciation rights. The latter were not tradeable assets and were fundamentally different from share options (Saunders v HMRC, 2025 UKUT 00374).
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