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Not such a good fit

JAN ELLIS examines the effect of the current capital gains tax regime on employee shares


  • Entrepreneurs’ relief does not apply to all EMI gains.
  • Risks of making an election under ITEPA 2003 s 431.
  • Share buy-backs by the company.
  • Care needed with loan notes and earn-outs.

I have long been a fan of enterprise management incentive (EMI) schemes which encompassed a pleasing light touch in terms of rules and regulations and a realistic set of parameters. Two men in very ill-fitting suits

These are available to many types of trading companies to a wide range of key people with a sensible maximum value (more generous than company share option plans). Best of all they fitted hand in glove with the now defunct taper relief.

Many of...

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