Our Tax team deal with employment tax issues on a daily basis. Employment tax spans both our advisory and transactional tax practices.
We advise employers and senior executives and managers on all aspects of tax efficient remuneration, including relocation and termination arrangements and equity based incentivisation.
Feedback indicates that our technical expertise in this complex area is considered to be first class. Our tax lawyers, employee incentive specialists and employment lawyers work together to provide a seamless service to our clients.
We regularly advise businesses and senior executives on:
- tax efficient remuneration (having regard in particular to the employment-related securities code and the impact of the disguised remuneration regime);
- tax planning for domestic and international relocation (including residency and domicile, dual contracts, share incentives, tax equalisation arrangements and payroll and social security issues); and
- termination and redundancy packages.
In recent years, the employment-related securities code and disguised remuneration provisions have added considerable complexity to remuneration arrangements. We have a high level of familiarity with the rules (and HMRC's stance and practice in relation to this area) and pride ourselves on being able to penetrate the complexity and produce robust and clear solutions. Working as a team we find practical solutions to complex problems and deliver advice clearly and concisely.
- management's equity in leveraged buyouts (together with assisting them with their CGT and personal tax planning);
- arrangements for owner-managers;
- the carried interest elements of fund structures; and
- tax efficient employee equity schemes (from Government-approved schemes such as "EMI" and "CSOP" through to bespoke structures such as "value" or "growth" shares).
Employment-related income returns often suffer tax at an effective rate of 52% or more; whilst CGT rates are generally at 28% and can be as low as 10% (due to entrepreneurs' relief) or even 0% (for some non-UK domiciled individuals). If a capital outcome can be achieved, there is the opportunity to make material tax savings. We are continually vigilant for such opportunities and, given our strong sector awareness, are often particularly well placed to identify possibilities when they may not be apparent.