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Thorny problems

16 April 2013 / Sara Cohen
Issue: 4398 / Categories: Comment & Analysis , Employees , Income Tax

The Office of Tax Simplification’s proposals for pruning unapproved share schemes


  • The OTS reports on unapproved share schemes.
  • Three structural changes are proposed to such schemes.
  • Future tax charges are proposed only when securities
  • are marketable.
  • Consistent treatment is required for internationally mobile employees.
  • A new employee shareholding vehicle is proposed.

The Office of Tax Simplification (OTS) published its final report on unapproved share schemes on 16 January 2013. The foreword says “This area of tax legislation has been like a poorly tended bramble patch. In trying to get at the delicious blackberries the unwary have found themselves snagged on the thorns of complexity a principal driver of which has been anti-avoidance legislation.”

The report contains six major recommendations (together with some supplementary ones) which if implemented will result...

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