Minutes of a meeting with the Inland Revenue on 5 December 2002

Minutes of a meeting with the Inland Revenue on 5 December 2002. Considers:


  • how the surrender of options will affect individual limits under EMI schemes;
  • when a change to a company’s articles of association will be considered a change to a key feature of a SIP;
  • restrictions on the types of shares which can be used in connection with a SIP;
  • how the rules for SIPs on rights issues will apply where a company has preference shares;
  • whether invitations to participate in a SIP are made on a rolling basis and how to treat new joiners;
  • whether it is possible to have different participating companies in a SIP for different parts of the plan (eg for free shares but not partnership shares);
  • electronic communications in relation to SIPs;
  • non-UK transactions which are equivalent to a scheme of arrangement;
  • exclusion of the Contract (Rights of Third Parties) Act in approved schemes;
  • whether an option scheme with a cash alternative provides a “right to acquire” shares;
  • Mansworth v Jelley.
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Keywords: Amending Plan Rules, Cash cancellation, CGT, Convertible securities, Corporation tax, Corporation tax deduction, CSOP, EMI, EMI disqualifying event, Employer's NICs, HMRC compliant plans, Income tax, NICs, PAYE, Readily Convertible Asset, Restricted securities, Rights issue, SAYE, Scheme of arrangement, SIP
Categories: Document archive, HMRC meetings