S431 elections

Issuing shares to employees – don’t forget s431 elections Employment related securities is probably one of the most tortuous areas of tax legislation. Contained in ITEPA 2003 it should be considered each and every time shares are issued or value shifts into...

SSE rules & company sales

Changes to Substantial Shareholding Exemption (SSE) rules open new possibilities on company sales Craig Simpson explores how the changes to the SSE rules can lead to an interesting decision for entrepreneurs selling a trading company. The market for company sales...

Rangers FC v HMRC

The Supreme Court has now published its decision in the long running tax case involving Rangers Football Club. The case centred on whether payments to an Employee Benefit Trust set up by the club for the benefit of players and executives should be treated as earnings...

Remunerating company owner managers

The conventional wisdom for many years has been to remunerate company owner managers by means of a small salary and the balance in dividends. The salary was normally pitched at just below the primary threshold – £8.164 in 2017/18. This might mean that some...

Salary Sacrifice Guidance

HMRC have published guidance on the salary sacrifice optional remuneration rules which took effect from 6 April 2017. The new rules largely see the withdrawal of the Income Tax and National Insurance benefit where an employee gave up a right to earnings in return for...