Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Rules definition

What does Rules mean? Rules describes the written provisions that govern how a pension scheme operates—especially occupational pension schemes—usually contained in, or annexed to, the trust deed (trust deed and rules). Legislation refers to these as scheme rules (for example, Pensions Act 1995 and Pensions Act 2004 in the UK, and the Pensions Act 1990 in Ireland). Scheme rules set out eligibility, benefit structure (defined benefit or defined contribution), contributions, service and accrual, retirement options and ages, revaluation/indexation, ill‑health and death benefits, transfers in and out, leaver provisions, forfeiture, augmentation, priority on winding‑up, discretions and decision‑making, and the scheme’s amendment and termination powers. They also...

ITEPA 2003: UK income tax, NICs and PAYE on unapproved employment-related share options: chargeable events, valuation, RCAs, roll-over, Apprenticeship Levy and reporting

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Practice notes

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Specific income tax rules

Specific income tax provisions (contained in sections 471–484 of the Income Tax (earnings and Pensions) Act 2003, Part 7, Chapter 5 (ITEPA 2003)) govern securities options that are connected with employment. These are the relevant provisions that usually bring unapproved share options within the scope of income tax. For broader guidance on unapproved options, see Practice Note: Unapproved share options. For details on employment‑related securities, see Practice Note: What is an employment‑related security? Alternative rules apply to options issued under the statutory tax‑advantaged share option schemes, namely enterprise management incentives (EMI), save as you earn (SAYE) and company share option plans (CSOPs). For more detailed guidance on the tax position of these options, see the following Practice Notes:

Enterprise management incentives (EMI)—income tax and NIC treatment of options
EMI—CGT, including business asset disposal relief and corporation tax relief
CSOP—income tax and NIC treatment of options
CSOP—CGT treatment and corporation tax treatment
SAYE—income tax and NIC treatment of options
SAYE—capital gains tax treatment of options

This Practice Note outlines the tax treatment of unapproved share options, which can be summarised as follows:

no liability to income tax (or National Insurance contributions (NICs) or the apprenticeship levy) arises...

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Web page updated on 21/05/2026

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