Employment Tax

Why use a company share option plan (CSOP)?

Produced by Tolley in association with Ken Moody
  • 19 Oct 2021 23:16

The following Employment Tax guidance note Produced by Tolley in association with Ken Moody provides comprehensive and up to date tax information covering:

  • Why use a company share option plan (CSOP)?
  • Background
  • Current limits
  • Uses of CSOPs
  • Tax benefits
  • Set-up costs
  • HMRC manuals

Why use a company share option plan (CSOP)?

Background

Until the mid-1990s, most larger companies were keen to take advantage of the benefits of what were originally known as Executive Share Option Schemes. The tax treatment was highly favourable, the scheme was relatively simple to understand and operate, and the limits were very generous. An employee was able to receive options to acquire shares in their employing company or the holding company of their employing group worth the higher of £100,000 or four times their salary.

Current limits

Under current legislation in ITEPA 2003, Sch 4, CSOPs are severely restricted with the maximum value of shares that can be put under option for any employee now limited to £30,000.

As such, they are regarded as of marginal benefit for senior executives and even for middle managers. CSOPs compare unfavourably with EMI where the limit is now £250,000, and also with non tax-advantaged alternatives where there is no limit, although the tax treatment is naturally less favourable.

However, while the focus is inevitably on the value of the shares at the time the option is granted, what really matters is the value when it is exercised. For example, if the shares have increased in

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