Private companies that implement share option schemes will often make use of 'exit-only' options, meaning that share options can only be exercised by participants when...
In 2011, anti-avoidance legislation in the form of Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) was introduced to tackle arrangements aimed at...
Introduction HMRC has, for many years, sought to ensure that the rewards gained from employment are properly subject to income tax and National Insurance contributions...
The huge volume of legislation that comprises Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) (the disguised remuneration rules) was introduced by...
Sections 554A–554AA of Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) are referred to by HMRC as the ‘gateway’ to the disguised remuneration legislation (this...
This Practice Note focuses on the meaning of a 'relevant step'. One of the requirements set out in the 'gateway' to the disguised remuneration rules (in section 554A of...
Under the disguised remuneration rules, the value of the 'relevant step' counts as employment income. For the meaning of a relevant step, see Practice Note: Disguised...
Employee benefit trusts (EBTs) are commonly used to support employees' share schemes and to provide other benefits to employees in the form of pensions and bonuses. Their...
Employee benefit trusts (EBTs) are a type of discretionary trust which are primarily established to enable companies to provide shares, cash or other benefits to their...
FORTHCOMING CHANGE: As originally announced at Autumn Budget 2017 and followed up by written statement after Spring Statement 2018, plus an announcement in Budget 2018,...
Relevance of the takeover code to share acquisitions by an EBT It may be necessary to consult the Takeover Panel (Panel) in certain circumstances if the trustee of an...
This Practice Note covers the application of the Investment Association (IA) remuneration principles to employee benefit trusts (EBTs). The principles are contained in...
FORTHCOMING CHANGE: As originally announced at Autumn Budget 2017 and followed up by written statement after Spring Statement 2018, plus an announcement in Budget 2018,...
FORTHCOMING CHANGE: As originally announced at Autumn Budget 2017 and followed up by written statement after Spring Statement 2018, plus an announcement in Budget 2018,...
Disguised remuneration and share schemes HMRC has, for many years, sought to ensure that the rewards gained from employment are properly subject to income tax and...
The disguised remuneration legislation was introduced in 2011 but has been further developed and extended by subsequent Finance Acts. It is intended to prevent the use of...