Note of a meeting with the Inland Revenue on 22 February 2000

Note of a meeting with the Inland Revenue on 22 February 2000. Considers:

  • Status of approval of letters to optionholders on takeover etc;
  • Option rollover – section 136 ICTA 1988
  • Definition of “scheme shares” – US limited liability companies and American Depositary Receipts;
  • Meaning of “ordinary shares” – section 832 ICTA 1988 – shares with no right to receive any dividend;
  • Restrictions in a Company’s articles of association and their impact for the purposes of being able to establish an approved CSOP;
  • Transfer Pricing;
  • Share Option Schemes – amendments to terms of share option – Application of Eurocopy and Reed Internationalcases;
  • Income tax charge under section 135 ICTA 1988;
  • Options granted at a discount – application of section 29(2) TCGA 1992;
  • Advance payment for the grant of an option;
  • Determination of “readily convertible assets” and meaning of “trading arrangements”;
  • PAYE and National Insurance – Cash Cancellation payments;
  • National Insurance Regulations – rollover of options;
  • Amendments to Section 165 TGCA 1992 – trusts;
  • Limited Partnerships – acquisition of partneship capital – application of section 79 Finance Act 1972.
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Keywords: BVCA Memorandum of Understanding, Cash cancellation, Corporation tax, Demerger, Discounted Options, EBT, Employee's NICs, HMRC compliant plans, Income tax, IPO, NICs, PAYE, Readily Convertible Asset, Restricted securities, Rollover, Takeover, USA
Categories: Document archive, HMRC meetings