RSUs and (non-)residency

A question about : RSUs and (non-)residency

I'm trying to understand how RSUs are taxed when someone becomes non-resident after a grant or when someone becomes resident after a grant during non-residency.

I found HMRC manual ERSM20300 but have trouble understanding the manual.

I understand that RSUs are seen as money's worth, which made me believe that they are taxed like cash bonuses, i.e. taxed in the year of receipt but you have to consider what period the bonus was for (i.e. which parts you were NR or R). Is this correct?

Specific scenario: end of year performance discussion in December 2013 for period January to December. 90 RSUs granted that will vest over 3 years, i.e. 30 in December 2014, 30 in Dec 2015 and 3 in Dec 2016. Became NR in February 2014 (still on UK payroll).

Type of RSU: received for no consideration; RSUs provide securities on vesting; and shares are not sold automatically when they vest.

How are the 30 shares received in December 2014 taxed in the UK? What is the period to consider? Initially, I thought Jan to Dec 2013 since that's my performance period. But after some reading, it seems RSUs are not for the performance period but an incentive to stay with the company, so they are earned between grant and vesting, i.e. December 2013 to December 2014 for the initial 30, December 2013 to December 2015 for the next 30, etc. Is this correct?

This would be pretty straightforward (like a bonus, just that the period it's for is different). But reading the HMRC it sounds like some RSUs granted while NR are not taxable in the UK at all, which contracts what I wrote before. The HMRC manual no RSUs refers to so many different chapter so this is really confusing.

I hope someone can help. Thanks!

Best answers:

• I understand that tax is held by the employer when the stock is vested and you should have been notified of that amount, so that you can make your tax return.
  Were you resident in this country and when did you become non resident. If you are non resident, which country are you resident in now. Have you sold any shares that were vested and is the copany a UK company or where based? The more information you give, the easier it is for help to be given.
  Sam
• I was granted 90 RSUs in December 2013. The first 30 vested in December 2014.
  I was UK resident until February 2014 when I became non-UK resident according to the SRT. I am still on the UK payroll. I am only concerned only about UK tax and I'm not a dual resident.
  It's a UK company which is a subsidiary of a US company. I received shares in the US company.
  You're correct that 47% tax was withheld when the shares vested. This showed up in my payslip.
  However, since I'm non-resident now, I believe that not all of this income is taxable in the UK. This is what I'm trying to figure out. Should I just treat it like any cash bonus? i.e. divide the period the RSUs were earned for into periods of R and NR? For the current vested RSUs, this would be December 2013 to December 2014. Should this be split into a period of December 2013 to February 2014 (taxable in UK) and February 2014 to December 2014 (not taxable in UK)? This is what I'd do for a cash bonus but I'm not sure it's the correct treatment for an RSU.
  Thanks for your help.