Clifford Chance

'Disguised Remuneration' Update Good news for employee share plans but action needed

7 July 2011

In revised "FAQs" published on 5 July 2011, HMRC confirmed its view on what will and will not constitute "earmarking" under the "disguised remuneration" (DR) legislation in the context of hedging arrangements for employee share plans (i.e. where shares are held in an EBT to satisfy awards granted by a company to its employees and directors).

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