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Share Options: All Change For UK Employees As Well

Nigel Doran tax partner at Macfarlanes discusses the final implications of Mansworth v Jelley for UK resident employees as well as inbound expatriates
The Revenue's appeal to the Court of Appeal in Mansworth v Jelley [2003] STC 53 has been dismissed and in a release recently published on its website the Revenue has said that it is not appealing against the decision. It is therefore final. The case concerns the computation of the capital gain accruing to a UK resident employee on the disposal of shares acquired by him upon the exercise of a share option which was granted to him by reason of employment before he became resident in the UK. Whilst the decision dramatically reverses long-standing Revenue practice relating to UK resident employees to whom...

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