Introduction to employee share schemes

This subtopic is intended as an introduction to employee share schemes for corporate tax lawyers. If further details are required, the advice of a share incentives specialist should be sought.

See the subtopic on Employment-related securities for detailed consideration of the tax treatment of shares, securities and unapproved securities options acquired in an employment context.

Introduction to share ownership schemes

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Introduction to employee share ownership schemes—which provides an introduction to employee share ownership schemes, details why companies use employee ownership models, provides a high-level description of the main types of share ownership arrangements used by UK companies and provides the background to employee ownership. The Practice Note also outlines some important issues to consider when implementing share scheme arrangements in UK companies
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The advantages and disadvantages of each share incentive arrangement—which seeks to highlight the main advantages and disadvantages of each of the nine most commonly utilised share incentive arrangements in the UK. The Practice Note details the advantages and disadvantages of the four main tax advantaged share schemes (enterprise management incentives (EMI) schemes, company share option (CSOPs) schemes, save as you earn (SAYE)

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Latest Tax News

Upper Tribunal upholds HMRC’s share loss relief enquiries and notices (Murphy v HMRC)

Tax analysis: In Murphy v HMRC, the Upper Tribunal (UT) dismissed the taxpayer’s appeal and allowed HMRC’s cross-appeal, finding that HMRC’s enquiries and closure notices relating to a claim for share loss relief claimed by the taxpayer and carried back to the previous tax year were validly made.

UT upholds FTT decision on principles of valuation and allocation of consideration in acquisition of care homes (Nellsar v HMRC)

Tax analysis: In Nellsar, the Upper Tribunal (UT) dismissed both parties’ appeals and affirmed the decision of the First-tier Tax Tribunal (FTT). In the context of acquiring care homes as a going concern, the purchase price should, on the basis of accounts compliant with generally accepted accounting principles (GAAP), be allocated to the care home properties using market value rather than depreciated replacement cost (DRC) for the purposes of corporation tax relief on amortisation of goodwill under the intangible fixed assets (IFA) regime and for the purposes of SDLT.

Tax weekly highlights—5 June 2025

This week's edition of Tax weekly highlights includes: (1) the UT decision in Nellsar on valuation, (2) the UT decision in Murphy on the validity of enquiries into share loss relief, (3) News Analysis on the FTT decision in Eyre on entrepreneurs’ relief, and (4) News Analysis on the UT decision in Scatola on the validity of enquiries into an SDLT avoidance scheme.

UT decides enquiries into SDLT avoidance scheme were valid (Scatola and others v HMRC)

Tax analysis: In Scatola, the Upper Tribunal (UT) dismissed the taxpayers’ appeal against closure notices charging stamp duty land tax (SDLT) resulting from a failed avoidance scheme. It also allowed HMRC’s cross-appeal in respect of an alternative discovery assessment.