SPL response to consultation on 5 recommendations from the OTS review of unapproved share plans

SPL response to the Government’s Consultation Paper of 24 May 2013 issued in response to the OTS review of unapproved employee share schemes. The five recommendations relate to the following:

  • share for share exchanges and rollovers;
  • the availability of corporation tax relief following takeover of a company;
  • the taxation of ERS awarded to internationally mobile employees;
  • section 222 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA), and the rules concerning the ‘making good’ of amounts paid by an employer in respect of tax on ERS; and
  • the valuation rules for listed company shares.
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Keywords: Corporation tax deduction, International, ITEPA 2003, Non-HMRC compliant plans, OTS, Restricted securities, Rollover, s.222 charge, Share valuation, Takeover
Categories: Document archive, Non-HMRC compliant share plans and arrangements, Tax and trust law issues