What is the background to the consultation on IMEs and ERS?
The NICs treatment of share awards held by IMEs has long been a complex area. This was recognised by the Office of Tax Simplification in 2013 when recommendations were made to simplify the NICs treatment and attempt to align this with the associated income tax position.
Earlier this month HMRC released its Summary of Responses from its consultation on the proposed changes to the NICs liabilities of IMEs with share awards.
What changes did FA 2014 make to the income tax rules for IMEs?
FA 2014 introduced a new Chapter 5B Pt 2 to ITEPA 2003 to take effect from 6 April 2015. The intention of the new rules is to broadly apportion the ERS gain of IMEs on a time basis over the vesting period of the award with the part which...
