Author Thomas Dalby
Edition 1st
Published July 2018
Length 300pp approx.
Suitable for Tax advisers, Employers
Price £85
ISBN 9781912386031

Employee Share Schemes


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The current regime for taxing employee shares can be traced back to FA 2003. This Act represented a complete revision of the relevant rules, and substantially amended the freshly re-written Income Tax (Earnings and Pensions) Act 2003.

The underlying principle of the FA 2003 regime is that value ‘gifted’ to an employee is taxed as employment income, while organic growth in the value of securities benefits from capital treatment.

That underlying principle is worked out through a series of approved schemes, each with its own advantages and restrictions. This book examines the different schemes and offers clear and practical guidance for employers considering the implementation of such schemes and for their professional advisers.

The author, Thomas Dalby, has more than 20 years' experience as a chartered tax adviser and as an employed barrister. Formerly a senior manager with Deloitte, Thomas is currently a director with Gabelle tax consultants, where he has worked since 2014. He has advised on the design and implementation of a wide variety of share option schemes.

Contents include:

  • Introduction
  • Scope and purpose
  • Formal and informal arrangements
  • Anti-avoidance
  • Paucity of case law
  • Part 1: Taxing Employee Shares
  • Legislative background
  • Valuation
  • Acquisition of securities
  • Changes in value
  • Charges on disposal
  • Company accounting and tax issues
  • Administration
  • Part 2: Share scheme practicalities
  • Design considerations
  • Shares (classes, restrictions, deferred consideration, company law)
  • Introduction to statutory schemes
  • Employee shareholder status
  • Enterprise management incentives
  • Company share option plans
  • Concluding remarks