Budget 2010 saw HMRC announce a consultation on 'geared growth' arrangements. Andy Goodman explains the impact on employee share incentives
The history
ITEPA 2003 was an early and welcome step in HMRC's tax law rewrite to bring simplification and clarity to the taxpayer. In the field of the taxation of employee equity ITEPA brought together various disparate provisions in various different acts into one distinct part (Part 7) and even gave us a catchy name — 'employment-related securities'. It seemed that its application from 6 April 2003 would make this a relatively clear and straightforward area for taxpayers and practitioners to navigate through.
Ten days later this principle of simplicity was abandoned when Finance Bill 2003 was published and we were presented with what became FA 2003 Sch 22. This completely rewrote ITEPA 2003 Part 7 those rewritten provisions generally applying from 16 April...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Budget 2010 saw HMRC announce a consultation on 'geared growth' arrangements. Andy Goodman explains the impact on employee share incentives
The history
ITEPA 2003 was an early and welcome step in HMRC's tax law rewrite to bring simplification and clarity to the taxpayer. In the field of the taxation of employee equity ITEPA brought together various disparate provisions in various different acts into one distinct part (Part 7) and even gave us a catchy name — 'employment-related securities'. It seemed that its application from 6 April 2003 would make this a relatively clear and straightforward area for taxpayers and practitioners to navigate through.
Ten days later this principle of simplicity was abandoned when Finance Bill 2003 was published and we were presented with what became FA 2003 Sch 22. This completely rewrote ITEPA 2003 Part 7 those rewritten provisions generally applying from 16 April...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
