Budget announcements on 23rd September 2022
These include:
Company Share Option Plan (CSOP) – From April 2023, qualifying companies will be able to issue up to £60,000 of CSOP options to employees, double the current £30,000 limit. The ‘worth having’ restriction on share classes within CSOP [presumably a reference to para 20, Sch 4, ITEPA 2003 – requirements as to other shareholdings] will be eased, better aligning the scheme rules with the rules in the Enterprise Management Incentive scheme and widening access to CSOP for growth companies.
This suggests that the class of shares to be put under CSOP options need not be either “employee-control” shares, or “open market shares”, allowing qualifying companies to grant CSOP options over a special class of restricted employees’ shares.
(There is no appetite then for enhancing the EMI share option regime.)
Repealing off-payroll working reforms – The 2017 and 2021 reforms to the off-payroll working rules (also known as IR35) will be repealed from 6 April 2023. From this date, workers across the UK providing their services via an intermediary, such as a personal service company, will once again be responsible for determining their employment status and paying the appropriate amount of tax and NICs.
David Pett, Tax Barrister 