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Draft Finance Bill 2016: Restricted stock units

Philip Paur (Deloitte) examines further changes affecting share incentives for internationally mobile employees, which take effect from April.
 
There has long been uncertainty over whether gains from restricted stock unit and similar plans are taxed as general earnings or securities option gains. Since April 2015 internationally mobile employees who are UK liable for only part of the earnings period have seen their income taxable gains time apportioned accordingly so the amount subject to income tax is the same either way. However from April 2016 for many the tax charge itself will shift from general earnings to specific employment income (ITEPA 2003 Part 7). This will have significant knock-on consequences for NICs CGT and the treatment of remittances (by non-domiciliaries). This article sets out what these changes are. All references are to ITEPA 2003 unless otherwise stated.
 

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