Changes to the thresholds contained in the EMI rules announced in the November 2025 Budget will come into effect shortly, on 6 April 2026. The effect of these changes is that some larger companies will be within (or back within) the EMI rules, meaning that they will be able to grant EMI options to their employees (either for the first time or once again). Generally these changes are to be...
Read moreThis week’s Budget was indeed a smorgasbord with a few surprise ingredients. Here are a few of the highlights:-You will be relieved to know that the trailed punitive tax measure to charge additional taxes on members of LLPs did not feature – a big relief for many and it shows that fierce lobbying by interested parties can sometimes do the trick. The tax relief on sales to EOTs will now be...
Read moreA recent case of a barrister being referred to the Bar Standards Board after being found to have relied on an AI tool without verifying the outputs, and citing non-existent cases in his pleadings, highlights the dangers practitioners can face when relying on AI. This will sound obvious to legal practitioners and tax advisers, but what about when members of the public or clients use AI? What...
Read moreAs has been widely reported on, the UK is introducing a new trading mechanism for private company shares – PISCES (Private Intermittent Securities and Capital Exchange System). Draft legislation has recently been published for Finance Bill 2026 which confirms that, for EMI and CSOP share options that are granted prior to Finance Bill 2026 receiving Royal Assent, it will be acceptable to make...
Read moreWe are seeing an increasing number of company sales where the sale proceeds are insufficient to pay out the full preference stack, such that the ordinary shareholders, often including management, would receive nothing or very little from the sale. It is not uncommon in this scenario for all parties to want ordinary shareholders to receive something. This may be partly so that everyone cooperates...
Read moreIn the Budget on 30 October last year, various changes were announced to the rules on sales to employee ownership trusts (EOTs). Most of the changes were aimed at tightening up the conditions for CGT relief, seemingly to address perceived abuse, examples being:-extending the period for disqualifying events (under which the CGT relief is withdrawn) from one to four tax years after the tax year...
Read moreWe noted in our Tax Bite of 31 October (https://parisitax.co.uk/blog/october-budget-implications-for-business-owners) the key changes to CGT rates announced in the budget the previous day, being:An increase in the main rate of CGT from 20% to 24% for sales on or after 30 October (and a change in the corresponding basic (lower band) rate from 10% to 18%); and Business asset disposal relief...
Read moreYesterday (30 October 2024) as you know Rachel Reeves delivered her much awaited first Budget. The big headline in terms of tax increases was, of course, the rise in employer’s NIC to 15% and the lowering of the level at which it applies, which together with the increase to the minimum wage adds significant costs to businesses. A sigh of relief was breathed that the main rate of CGT will rise...
Read moreIn this Tax Bite, we give you a refresher on section 431 elections, with a focus on practical points and tips for transactions. Background – what are s431 elections and what do they do? Almost all shares acquired by a director (including a non-executive director) or employee of a company (or anyone connected with any such person) will be employment-related securities for tax purposes, bringing...
Read moreWhere business asset disposal relief (BADR) is available and claimed, it reduces the rate of capital gains tax (CGT) on the sale of the asset (e.g. shares), subject to a lifetime limit of £1 million of gains. Based on the rates of CGT currently in force, the rate of CGT drops from 20% to 10%, so the saving is significant. As with all reliefs, a number of conditions have to be satisfied in order...
Read moreDemergers are popular as a way of separating trades / businesses (including investment businesses) in a tax efficient manner. They can be used in preparation for a sale, prior to an investment, or just as a commercial strategy to ring-fence one business or asset base from another. Broadly, provided they are correctly structured they can allow for this with no or minimal tax leakage. Over time...
Read moreTax Bite – EMI share valuations – recent developments In addition to the considerable tax benefits of enterprise management incentive (EMI) options, the ability to agree with HMRC the market value of shares to be placed under EMI options is another really attractive feature of this type of share incentive. Outside of EMI and CSOP options, it is generally not possible to seek HMRC’s agreement to...
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