Employment-related securities

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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
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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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?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...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Employment-related securities content

Q&As
Where an individual acquires shares in a company and is a director and an employee of the company how should the section 431 election be completed?To...
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16th Aug
Q&As
Does HMRC need to be notified of a section 431 of the Income Tax (Earnings and Pensions) Act 2003 election?It is possible for an employee (or...
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16th Aug
Q&As
If a shareholder reinvests the proceeds of a previous company sale in a new company, through their personal limited company, should they (or can they)...
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16th Aug
Q&As
If the 14-day deadline for making a valid restricted securities election under section 431 of the Income Tax (Earnings and Pensions) Act 2003 is...
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16th Aug
Q&As
If (post-transaction) HMRC agrees a valuation for shares, and those shares are then sold on at a higher value, can HMRC go back on the agreed...
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16th Aug
Q&As
When making a section 431 election under the Income Tax (Earnings and Pensions) Act 2003, is it necessary to obtain a professional valuation, or can...
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16th Aug
Practice notes
Convertible securities—definitionConvertible securities are: • employment-related securities (see: What is an employment-related security?)•with the...
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15th Aug
Practice notes
Notional payments not made good—the section 222 chargeThe income tax charges associated with employment-related securities and securities options...
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15th Aug
Practice notes
Restricted securities—tax treatment and joint electionsThe rules applying to directors and employees in relation to restricted securities contained...
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15th Aug
Practice notes
Securities options—income tax treatmentSpecific income tax rules (at sections 471–484 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003))...
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Produced in partnership with Graham Muir of CMS 15th Aug
Practice notes
Post-acquisition benefitsThis note deals with the specific rules contained within sections 447–450 of Income Tax (Earnings and Pensions) Act 2003...
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15th Aug
Practice notes
Securities disposed of for more than market valueThis note deals with the specific rules contained within sections 446X–446Z of Income Tax (Earnings...
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15th Aug
Practice notes
Corporation tax relief for employee share and share option acquisitionsAn employing company is entitled to corporation tax relief, under a specific...
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15th Aug
Practice notes
Employment-related securities—reporting obligationsEmployers (or other responsible persons) are required to provide specified information to HMRC in...
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15th Aug
Practice notes
What are restricted securities?The rules applying to directors and employees in relation to restricted securities contained within Chapter 2, Part 7...
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15th Aug
Practice notes
Internationally mobile employees and employment-related securities (pre-6 April 2015) [Archived]ARCHIVED: This Practice Note has been archived and is...
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15th Aug
Practice notes
NICs implications of employment-related securities and securities optionsThe stated purpose of National Insurance contributions (NICs) is to fund and...
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15th Aug
Practice notes
PAYE implications of employment-related securitiesPay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions...
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15th Aug
Practice notes
NICs—employers' recovery from employees—general prohibition and specific exceptionsThere are currently seven different classes of National Insurance...
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15th Aug

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