Company share option plans (CSOP) and enterprise management incentives (EMI) are two statutory share option regimes that can be used to incentivise employees in a tax-efficient way. Broadly, where the relevant qualifying criteria have been met, both the CSOP and EMI schemes allow employees to acquire shares in their employer
Richard Miller is a partner in the Tax Department and a member of the Private Funds, Private Equity Transactions and Mergers & Acquisitions Groups.
Richard provides advice on a full range of UK and international tax matters. His practice specifically focuses on all aspects of the private fund lifecycle.
Richard acts for private fund asset managers in structuring and raising investments funds, structuring carried interest and coinvestment arrangements, establishment and operation of fund management businesses, M&A and investment activity and finance transactions.
Richard also represents institutional investors in structuring and negotiation their private fund investment activity including primary and secondary investments and bespoke transactions.
As has been widely reported, a number of the Mini Budget proposals (summarised in our recent Tax Blog) have been scrapped. The new Chancellor of the Exchequer Jeremy Hunt announced these measures claiming that they are estimated to raise £32 billion in taxes every year. More tax rises and…
UK Mini Budget 2022
The Chancellor today unveiled the UK’s 2022 Growth Plan which has been described as being “the biggest package of tax cuts in generations”. We have summarised here the tax changes that we think will be of interest to our client base.
- UK corporation tax: the main
The UK has now been in lockdown, on and off, for the best part of a year. With the COVID-19 vaccination programme now in full swing in the UK, and hopefully with light at the end of tunnel, attention has inevitably turned to the question of “how are we going…
On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and in the future.
In the last year or so, we have regularly written…
Following the UK general election on 8 June 2017, at which Theresa May’s Conservative party won the largest number of seats but lost its overall majority, the Queen’s Speech setting out the now minority Conservative government’s legislative programme for the next two years was delivered on 21 June 2017 at …
In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”).
One area that the OECD has itself acknowledged requires further consideration is in relation to BEPS Action 6, the final report on which was published in October 2015, which seeks to prevent access to treaty benefits in inappropriate circumstances (“treaty shopping”).
The final report on Action 6 included various proposals designed to prevent treaty shopping, including the proposed introduction into double tax treaties of:
- a limitation on benefits (LOB) rule that limits the availability of treaty benefits to entities that meet certain conditions
- a general anti-abuse rule which looks at the principal purpose of the transactions or arrangements in question (the principal purpose test, or PPT),
with the OECD recommending that as a minimum standard either (i) a PPT, or (ii) a PPT with either a “simplified” or “detailed” LOB provision should be adopted.
The European Commission has expressed a general preference for the PPT rather than the LOB provisions. HMRC have indicated that the UK will not adopt the LOB.