The background to the introduction of income tax on employee share options

Abstract

Using Treasury and Inland Revenue files from the National Archives, this article traces the developments leading to the introduction of the first set of UK provisions specifically designed to charge profits from the exercise of employee share options as income. It examines how the Revenue discovered a potential problem in their interpretation of existing general legislation and their reaction to the loss of a test case in the House of Lords. It gives an insight into how policy in the area was formulated and into the relationship between the Revenue and Treasury Ministers who, even though knowledgeable on the subject, found themselves persuaded to act almost completely in accordance with the Revenue's views.