Minutes of a technical meeting with the Inland Revenue on 29 November 2004

Minutes of a technical meeting with the Inland Revenue on 29 November 2004 regarding the following:

  • the application of Chapter 3C, Part 7, ITEPA to shares acquired under Inland Revenue approved schemes;
  • the taxation of SAYE options once the scheme has ceased to be approved;
  • amending approved options without the relevant scheme losing approval which includes a discussion of reconciling CIR v Eurocopy with the decision in CIR v Reed International plc;
  • how the system for Inland Revenue approval numbers is intended to operate;
  • the recovery of employer’s Class 1 NICs on benefits paid by an employee benefit trust or other third party;
  • the recovery of employer’s NICs on “notional payments”;
  • the position regarding NICs liabilities following the transfer of a business;
  • the tax position on the exercise of an undervalue EMI option;
  • the availability of deductions in relation to EMI options;
  • UK/UK transfer pricing guidance and applicability of these rules to options granted before 1 April 2004;
  • availability of relief under Schedule 23, Finance Act 2003 on sale of business; and
  • scope of reporting requirements under Schedule 22 and what constitutes a reportable event.

The following additional administrative points were discussed at this meeting and are summarised in the minutes: (1) the Inland Revenue’s move to new offices; and (2) the updating of the Inland Revenue’s website, in particular the manuals.

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Keywords: Amending Plan Rules, Change of Control, Corporation tax, Corporation tax deduction, CSOP, EBT, EMI, Employee's NICs, Employer's NICs, Employment-related security, Good Leaver, HMRC compliant plans, Income tax, IPO, ITEPA 2003, NICs, PAYE, Rights issue, SAYE, SIP, Takeover, Tax reporting, Transfer pricing
Categories: Document archive, HMRC meetings