When does the exercise of discretion result in the loss of beneficial EMI tax treatment? Ian Shaw (Korn Ferry) critiques HMRC’s long-awaited guidance.
EMI options are one of the most attractive incentive schemes offered by medium to high tax jurisdictions allowing small high-growth companies to compete to recruit and retain top talent against bigger players who can offer far larger base salaries and cash bonuses. They combine the ‘one-way bet’ of an option with the employee required to pay nothing upfront with the beneficial tax treatment of owning shares in a way which qualifies for business assets disposal relief.
Access to such beneficial tax treatment is quite rightly guarded by various conditions including as to which companies may grant and which employees may receive EMI options and the terms of those options. On the latter the legislation requires an...
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When does the exercise of discretion result in the loss of beneficial EMI tax treatment? Ian Shaw (Korn Ferry) critiques HMRC’s long-awaited guidance.
EMI options are one of the most attractive incentive schemes offered by medium to high tax jurisdictions allowing small high-growth companies to compete to recruit and retain top talent against bigger players who can offer far larger base salaries and cash bonuses. They combine the ‘one-way bet’ of an option with the employee required to pay nothing upfront with the beneficial tax treatment of owning shares in a way which qualifies for business assets disposal relief.
Access to such beneficial tax treatment is quite rightly guarded by various conditions including as to which companies may grant and which employees may receive EMI options and the terms of those options. On the latter the legislation requires an...
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: