Tax treatment

Tax treatment guidance:

When a person disposes of an asset and makes a profit that is capital in nature, this has the potential to be a taxable capital gain. It may be possible to avoid a tax...

Practice Note

Entrepreneurs' relief is a capital gains tax (CGT) relief designed to encourage individuals to set up and expand their own businesses. Provided that the conditions are...

Practice Note

Convertible securities are: • employment-related securities (see: What is an employment-related security?) • with the capacity to convert into securities of a different...

Practice Note

This note explains the income tax treatment of convertible securities. The definition of convertible securities is set out in Convertible securities—definition. The basic...

Practice Note

Corporation tax deduction for costs incurred in setting up and operating employee share schemes Costs incurred in setting up and operating an employees’ share scheme may...

Practice Note

This Practice Note describes the rules on the disclosure of tax avoidance schemes (DOTAS) applying to income tax, corporation tax, capital gains tax (CGT) and National...

Practice Note

This Practice Note covers the procedural aspects of the rules on the disclosure of tax avoidance schemes (DOTAS) applying to income tax, corporation tax, capital gains...

Practice Note

An earn-out is a particular way of structuring the consideration payable for the acquisition of shares in a company (the Target) where at least part of the price is to be...

Practice Note

Employment-related securities and securities options The definition of an employment-related security is broadly any security (which includes shares, certain rights under...

Practice Note

Employers (or other responsible persons) are required to provide specified information to HMRC in relation to reportable events involving employment-related securities or...

Practice Note

Entrepreneurs' relief Entrepreneurs' relief (ER) is a capital gains tax (CGT) relief designed to encourage individuals to set up and expand their own businesses. Provided...

Practice Note

Background Entrepreneurs’ relief (ER) is available for shares in trading companies provided the conditions in sections 169H–169SH Taxation of Chargeable Gains Act 1992...

Practice Note

The procedure for making joint restricted securities elections is the same regardless of whether the election is made under section 425(3), 430 or 431 of the Income Tax...

Practice Note

This Practice Note: • illustrates the partnership structure of a typical onshore limited partnership fund • explains what carried interest is, and • describes the tax...

Practice Note

This Practice Note explains the rules that apply to distributions made to UK resident and domiciled individuals on or after 6 April 2016. The way in which individuals are...

Practice Note

HMRC consists of specialist departments dealing with specific areas of employment related securities (ERS) and share schemes. The specific HMRC department to contact...

Practice Note

The UK has a comprehensive code for the taxation of employment income. This Practice Note deals with the basic principles of income tax on employment income and how they...

Practice Note

In addition to cash earnings, such as wages or salaries, many reward packages include non-cash items, such as the provision of a car, health insurance or childcare. An...

Practice Note

Where an employee or director acquires, holds or disposes of shares or securities in connection with his or her employment, income tax on employment income can arise...

Practice Note

What is an LLC and how is it different to other forms of business organisation? A limited liability company (LLC) is a legal form of business organisation in US. A US LLC...

Practice Note

The stated purpose of National Insurance contributions (NICs) is to fund and enable eligibility for certain state benefits, such as the state pension, and other social...

Practice Note

The stated purpose of National Insurance contributions (NICs) is to fund certain state benefits such as the State Pension, as well as other social security benefits such...

Practice Note

The stated purpose of National Insurance contributions (NICs) is to fund certain state benefits such as the State Pension, as well as other social security benefits such...

Practice Note

The income tax charges associated with employment-related securities and securities options typically arise upon acquisition of securities, or because an amount of...

Practice Note

The concept of ordinary share capital is important for UK tax purposes. This Practice Note sets out the key tax reliefs that require ordinary share capital (whether...

Practice Note

Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must be withheld and...

Practice Note

Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must be withheld and...

Practice Note

This note deals with the specific rules contained within sections 447–450 of Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) (Part 7, Chapter 4), which subject...

Practice Note

The rules applying to directors and employees in relation to restricted securities contained within Chapter 2, Part 7 of Income Tax (Earnings and Pensions) Act 2003...

Practice Note

This practice note deals with the specific rules applying to employment-related securities acquired for less than market value contained within Chapter 3C, Part 7 of...

Practice Note