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Share plans are increasingly popular as employee incentive arrangements and multinational businesses often offer participation to employees in several jurisdictions. This can lead to administrative and tax headaches, so the purpose of this note is to set out the key issues which an overseas employer needs to consider when extending their share plan to UK employees or executives.

Some companies offer global plans on the same terms to all employees wherever resident. These organisations need to ensure that they understand the regulatory requirements in the jurisdictions in which they operate and that they deal with these and, in particular, tax withholding requirements. This is to ensure that neither the employees nor the employer have a nasty (and potentially costly) surprise waiting for them in the form of interest and / or penalties which could negate the incentivising effect of the award.

Other organisations seek to make use of local tax advantaged arrangements which typically take the form of sub-plans which operate under an ‘umbrella’ plan which includes the