Minutes of a meeting with the Inland Revenue on 11 November 1998

Minutes of a meeting with the Inland Revenue on 11 November 1998. Considers the following:

  • clawback of tax relief under QUESTs;
  • cash cancellation payments by QUEST trustees;
  • capital gains tax for QUEST trustees on disposal of shares and application of D35 to QUESTs;
  • the period within which money received by QUEST trustees must be spent;
  • meaning of “reconstruction or amalgamation” for the purposes of approved schemes;
  • the relationship of the requirement for participants in approved schemes to be full-time and the Companies Act meaning of employees’ share scheme;
  • whether the company can retain discretion as to the exercise of options under a Sharesave Scheme which are more than three years old;
  • the position of SAYE optionholders who leave an associated company before the maturity of their options;
  • how rolled over options count towards the £30,000 limit for CSOPs;
  • the application of Section 140A ICTA to LTIPs.
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Keywords: Bad Leaver, Cash cancellation, CGT, Change of Control, Clawback, Corporation tax deduction, CSOP, Forfeiture, Good Leaver, HMRC compliant plans, Income tax, Leavers, NICs, PAYE, Performance condition, Profit Sharing Scheme, Reorganisation, Retirement, Rollover, SAYE, Takeover
Categories: Document archive, HMRC meetings