2023–24—Budget and Finance Bill

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This Overview guides practitioners to analysis and source materials on the UK 2023–24 Budget and Finance Bill as they relate to employee share incentives.

Fiscal events in 2023–24 made targeted amendments to the tax‑advantaged plans in Part 7 ITEPA 2003. The Finance (No. 2) Act 2023 doubled the CSOP individual limit to £60,000 from 6 April 2023 and removed certain restrictions on the class of shares eligible for CSOP options. For EMI, legislation implemented simplifications from April 2023 to the option grant process (including removal of the need to set out share restrictions in the option agreement and to obtain a signed working time declaration), with the notification deadline moving to 6 July following the end of the tax year for options granted from 6 April 2024. Practitioners should also note HM Treasury and HMRC’s call for evidence on SIP and SAYE and the government’s response signalling administrative streamlining.

Key issues include updating plan rules and grant documentation, managing transitional options, ensuring compliance with revised EMI notification and ERS annual returns, and considering interactions with PAYE and NICs following threshold and rate changes announced alongside the Budgets....

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