Do I owe tax where I used to live if RSUs vest after moving?
Very likely a share of it. In most systems the taxing point for restricted share units is vest, and the benefit is apportioned by workdays over the vesting period, so the days worked in the country you left carry their share even though you were living elsewhere when the units vested. The country you moved to taxes its own share. Neither position is a mistake to be argued away; the work is establishing the split, getting the former country's withholding right and claiming the credit correctly in the new one.
How is an RSU vest split between two countries?
By workdays over the vesting period. The apportionment runs from grant to vest for the tranche in question, and each country taxes the share of the benefit attributable to the days worked there, at its own rate. Because tranches of the same grant vest on different dates, they can each carry a different split, and a single answer for the whole grant is usually wrong. Work it tranche by tranche, from the vesting schedule and a day record of where the employee actually worked, and keep the working paper.
Which payroll withholds when an employee vests after transferring?
Both may have something to do. The former country generally has withholding on the share attributable to the days worked there, and the new country deals with its own share, so the two mechanics have to line up rather than one replacing the other. The awkward part is that the former payroll may no longer carry the person and has to be told a vest is coming. An employer should know, for each unvested tranche, which country's share it will generate and which payroll has to act on the vest date.
Can I claim credit at home for tax the other country took?
That is the intended mechanism, and it works when the two sides are consistent: the same benefit, the same period, recognised by both countries. The two things that break it are an apportionment the countries do not agree on, and withholding in the former country that was never properly reported, because a credit claim needs evidence of the tax actually borne on the share in question. So the credit is only as good as the workday split and the withholding documentation behind it. Settle both before filing rather than after the claim is queried.
Are RSUs taxed when they vest or when I sell the shares?
For the employment benefit, most systems tax at vest, which is why the date you moved matters so much: the split is fixed by where you worked across the vesting period, not by where you happened to sell. What happens on a later disposal of the shares is a separate question with its own answer in each country, and it should not be mixed up with the vest. Deal with the vest and its apportionment first, because that is the event the two payrolls and the credit claim all turn on.
What records do we need for a workday apportionment over vesting?
The vesting schedule, so each tranche's own period is clear, and a day record of where the employee worked across it. Travel bookings, calendars and immigration records are the practical sources, and they should be collected while a transfer is happening rather than at a vest years later. Keep the working paper that converts the day count into the split for each tranche, with the dates it relied on. An apportionment nobody can reproduce is the weakest part of an otherwise sound position when either country asks about it.
Is the sale of foreign property taxable where I live?
For a resident, yes — worldwide gains are taxable, and the gain is computed in your own currency, so the exchange rate at purchase and at sale changes the number even when the local-currency price did not move. The country where the property sits usually taxes it too, often with a withholding or clearance step before closing, and that tax becomes a credit. A principal residence relief may apply to a home abroad on the same terms as one at home. See principal residence and foreign property.
What is a permanent establishment, and how easily do we create one?
A taxable presence in another country under the treaty — typically a fixed place of business such as an office, branch, factory or workshop, or a dependent agent habitually concluding contracts on your behalf. Some treaties add a services test measured in days. Purely preparatory or auxiliary activity is excluded, but that carve-out is narrower than it sounds: one senior employee working from home in the other country, with authority, has been enough. See business profits and permanent establishment.
