Untracked, private seller. I ordered this card from my own country and has not arrived. In the meantime I received cards from Germany (took less than a week), Japan (maybe two weeks) and France (nearly a month).
I don't get what my options are. Is the seller going to see it and decide whether to refund or not? Should I contact cardmarket itself?
Hi all.
Let us assume the following situation:
An individual was granted a compensation plan including stock options and RSUs while UK resident.
They then left the UK and became non-resident. While non-resident, the options were exercised and the RSUs vested (paying income tax in the UK at source according to the proportion of days employed in the UK), so the shares, I suppose, were acquired at that point. Still non-resident, they sold the shares.
They have now returned to the UK within 5 years, and the sale of the shares took place in the overseas part of the split year of return.
The relevant law should be the 1992 TCGA.
My reading of the law, after doing some research: For CGT, the asset is the shares, not the grant or the option/RSU itself. Section 1M would normally pull gains made during a temporary period of non-residence into charge in the year of return, but section 1N excludes assets acquired during that period provided the four conditions in s 1N(1) are met and s 1N(2) is not engaged. Namely:
(a) the asset was acquired by the individual in the temporary period of non-residence; (b) the acquisition was not by means of a disqualifying no gain/no loss disposal (i.e. not a transfer under s 58, s 73 or s 258(4)); (c) there is no reduction in the acquisition consideration under the rollover-type provisions in ss 23(4)(b) or (5)(b), 152(1)(b), 153(1)(b), 162(3)(b) or 247(2)(b) or (3)(b) by reference to a UK resident disposal; and (d) the asset is not an interest created by or arising under a settlement.
The exclusion is then switched off by s 1N(2) where the asset disposed of is a "new asset" whose gain or loss is computed by reference to an "old asset" under s 116(10)/(11), s 134 or s 154(2)/(4), and the new asset would qualify for the exclusion but the old asset would not.
On the timing point, s 1M(6) sends you to Part 4 of Schedule 45 FA 2013, and paragraphs 111–113 together mean that the "temporary period of non-residence" continues right up to the start of the UK part of the split year, so a disposal made in the overseas part of the split year of return is still within the protected window.
My provisional conclusion: The shares were both acquired and disposed of within the temporary period of non-residence, all four limbs of s 1N(1) appear satisfied, and s 1N(2) is not in play because there is no "old asset" feeding into a "new asset" via a reorganisation. So the gain should fall outside s 1M and there should be no UK CGT on return. The fact that the plan was granted while UK resident strikes me as irrelevant for CGT, because a grant is not an asset.
Where I'd value input:
Thanks!
Ciao, ho un dubbio riguardante la residenza fiscale.
Poniamo il caso in cui uno si sia trasferito in Australia per due anni, iscritto AIRE, con regolare contratto da lavoro dipendente locale, vivendo in casa in affitto, con bollette, investimenti presso banche locali, vita regolare lì insomma.
In quei due anni però passava circa 100 giorni l'anno in Italia in totale stando dai genitori, durante periodi festivi tipo Natale e estate, aggiungendo poi qualche settimana di lavoro remoto prima di tornare all'estero.
L'anno successivo dopo i due anni ha chiesto trasferimento all'azienda per lavorare da remoto in Italia, con nuovo contratto con la srl italiana. Si è quindi trasferito tornando alla casa dei genitori, cambio di residenza all'anagrafe, apertura di conto italiano che prima non aveva e quant'altro.
Esiste un caso in cui si possa sostenere la residenza italiana nei due anni australiani? Oppure sono paranoie? Questo prima del 2024 quindi prima dei cambiamenti avvenuti alla residenza fiscale di cui ho letto partono dal 2024 in poi.
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