The Budget contains revisions to the rules for employment related securities relating to people who are resident but not ordinarily resident in the UK. These rules get so close to making the private equity carry chargeable to income tax for some non-domiciled people.

But then you have to remember that the BVCA rules deem the carried intrest in private equity to not be employment related securities, even though they obviously are.

So near. So close. So far to go to creating fair taxation.