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Since the last edition of this Book in 2008 there have been considerable changes to the share schemes landscape.
The two drivers of improving remuneration efficiency and increasing employee commitment have seen an increased interest in such matters by both government and companies in recent years. The work undertaken by the Office of Tax Simplification has als: prompted a number of improvements to the legislative framework.
This book provides commentary on all the current tax-advantaged share schemes that is both authoritative and readable - a single volume giving the reader (whether they are a seasoned share schemes adviser or a novice in such matters) what they need to know about each type o. scheme, and up to date with the considerable changes in Finance Acts 2013 and 2014. Under ths 'tax-advantaged' umbrella too is a section on the Employee Shareholder Shares regime. Since iinception in September 2013, the potential benefits of this regime have attracted considerable attention from practitioners.
The book also covers the variety of unapproved arrangements and other diverse matters and tax provisions that can apply to employee shares. One of the most recent developments, included here are the reliefs introduced in 2014 for the new category of 'Employee-Ownership Trust'.
The discussion is not confined to the legal provisions, but also highlights some of the practical issues that come into play. Examples include comment on: agreeing share values for EMI optior grants; the need to 'issue' shares in order for them to be 'Employee Shareholder Shares' (not something apparent from the ITEPA legislation!); an often overlooked view on quantum of sale proceeds from restricted shares falling to be taxed under ITEPA 2003 s. 428; the general law of restitution as it applies to recovery (from the employee) of PAYE for which the employer has to account in connection with 'share-based remuneration'; and whether (and how) earn-out consideration might be brought within the 10% Entrepreneurs' relief rate of CGT.
Also, in the Appendices selected official guidance, pro-forma documentation and HMRC forms (referencing the latest spreadsheet templates) are reproduced.
