HMRC comment on share plan implications of Murray case.
Download - (requires membership login)SPL submission from February 2014 regarding the draft legislation on tax incentives for employee ownership trusts for the Finance Bill 2014 published by HMRC and HM Treasury on 10 December 2013.
The draft legislation to which SPL's comments relate is attached to the end of the submission.
Download - (requires membership login)SPL submission dated 20 June 2013 commenting on revised draft of Inheritance Tax Manual, section 42900 onwards relating to employee benefit trusts which was circulated by HMRC in June 2013 prior to publication of the revised manual on 1 July 2013.
Included in the attached copy of the submission is:
Not included in the attached document but referred to in the response and available in the "Trusts" section of this Knowhow Archive are:
Revised draft of Inheritance Tax Manual, section 42900 onwards relating to Employee benefit trusts which was circulated by HMRC in June 2013 prior to publication of the revised manual on 1 July 2013
Download - (requires membership login)File note of a conversation with the Inland Revenue Capital Taxes Office in respect of section 86 Inheritance Tax Act 1984 and section 72(2)(c) Inheritance Tax Act 1984.
Download - (requires membership login)