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Residence and Domicile Reform

 
Nigel Doran partner in the corporate tax group at Macfarlanes LLP considers the changes to the taxation of share-based remuneration brought on by the recent residence and domicile reforms
 
Much ink has been spilled in the national press in recent months on the Chancellor's reform of capital gains tax and the closely-linked reform of residence and the remittance basis for non-UK domiciliaries. There have also been a fair few articles in the tax press (notably The Tax Journal) on these topics. This is not the place to add to the Chancellor's woes or to consider those topics any further. However what I will do in this article is consider the changes to the taxation of employment-related securities which have come a little unexpectedly in the wake of these other reforms. This...

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