Employment-related securities

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Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Employment-related securities content

Practice notes
Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must...
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15th Jan
Practice notes
This note deals with the specific rules contained within sections 446X–446Z of Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003 ) (Part 7,...
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15th Jan
Practice notes
Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must...
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15th Jan
Practice notes
There are currently seven different classes of National Insurance contributions (NICs). The type paid depends on the individual's employment status,...
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15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.Following recommendations of the Office of Tax Simplification and an HMRC...
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15th Jan
Practice notes
The income tax charges associated with employment-related securities and securities options typically arise upon acquisition of securities, or because...
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15th Jan
Practice notes
Determining whether an employment-related security exists is a crucial step in determining whether the specific (and sometimes punitive) income tax...
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15th Jan
Practice notes
The rules applying to directors and employees in relation to restricted securities contained within Chapter 2, Part 7 of Income Tax (Earnings and...
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15th Jan
Practice notes
The rules applying to directors and employees in relation to restricted securities contained within Chapter 2, Part 7 of Income Tax (Earnings and...
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15th Jan
Practice notes
The stated purpose of National Insurance contributions (NICs) is to fund and enable eligibility for certain state benefits, such as the state pension,...
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15th Jan
Practice notes
Specific set income tax rules (contained in Part 7, Chapter 5 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003)) apply to securities...
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15th Jan
Practice notes
An employing company is entitled to corporation tax relief, under a specific set of rules in the Corporation Tax Act 2009 (CTA 2009), in relation...
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15th Jan
Practice notes
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...
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15th Jan
Practice notes
This practice note sets out the key considerations and illustrative computations for determining whether to elect under section 425 or section 431 of...
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15th Jan
Practice notes
This practice note deals with the specific rules applying to employment-related securities acquired for less than market value contained within...
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15th Jan
Practice notes
This note explains the income tax treatment of convertible securities. The definition of convertible securities is set out in Convertible...
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15th Jan
Practice notes
Where an employee or director acquires, holds or disposes of shares or securities in connection with his or her employment, income tax on employment...
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15th Jan
Practice notes
Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must...
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15th Jan
Practice notes
An earn-out is a particular way of structuring the consideration payable for the acquisition of shares in a company where at least part of the price...
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15th Jan
Practice notes
Convertible securities are: • employment-related securities (see: What is an employment-related security?)•with the capacity to convert into...
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15th Jan

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