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Corporate structuring is a tax-driven science.
Taking effect from 6 April 20207
EMI2 (expanding on the existing regime)
- The CSOP individual option limit will be increased to £120,000.
- The interaction between the CSOP and EMI individual options limits will be removed.
- The CSOP exercise period will be extended to 15 years.
- The period for certain tax-advantaged and non-tax advantaged shares and share options reserved by third parties to be excepted from the disguised remuneration rules will also be extended to 15 years.
- The exception for Employee Ownership Trusts (EOTs) in the EMI rules will be extended to companies arranging to become controlled by an EOT.
- The EMI exercise window following disqualifying events will be extended to 180 days.
Founders Relief
- For Founders and significant early investors in high-growth, innovative UK companies.
- Tax rate of 10% Capital Gains Tax.
- Up to £10 million of qualifying gains per individual.
- Applies to qualifying disposals made on or after 6 April 2027.
This new condition is what separates Founders' Relief from older tax reliefs. To qualify, your company must meet specific benchmarks for scale and novelty, which will likely align with the SEIS or EIS schemes and/or meeting HMRC's "Knowledge-Intensive Company" definition, which requires a heavy, proven percentage of operating costs to go into R&D or intellectual property creation.
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