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KEN MOODY carves his way through the mire of recent legislation relating to employment-related securities in a quest to discover the meaning of 'grandfathering'.
KEY POINTS
- HMRC's new chapter on employment-related securities for their ERS Manual.
- The meaning of 'grandfathered'.
- Are securities acquired within any of the chapters of Part 7 of ITEPA 2003?
- Purpose of ITEPA 2003 s 447(4).
- Effect of incorporation.
THE LONG-AWAITED chapter of HMRC's Employment Related Securities Manual on post-acquisition benefits taxable under ITEPA 2003 Part 7 Chapter 4 was released on 7 December 2006. The new material numbered paragraphs 90000 to 91040 is not yet listed in the manual's main contents page and may be found in the updates (for some reason the date is shown as 10 January 2007).
The introduction to the chapter recites the legislative history and principal changes then states that 'There is no grandfathering of securities acquired before 16...
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