Our client, an Irish citizen, has been tax resident in the UK for a number of years. His Irish based limited trading company, of which he has been a director for 11 years,is winding down and will be liquidated shortly.
1 Can the company give a tax free termination of employment payment to our client, even though he is currently non resident for tax purposes?
2 If so, what would the tax treatment of this be in the UK? Would it be tax exempt in the UK because it tax free in Ireland?