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Notionally NICable?

There may be a gaping hole (or two) in the NIC rules on share incentives that stems from anti-avoidance action and incomplete attempts at harmonisation of tax and NIC rules. David Heaton explores the arguments
The question was raised as a result of a Large Business Service review of a newly acquired client's share scheme. One of the major moneyspinners for the LBS team currently working its way through UK PLC's 9 000-plus share schemes is the charge in ITEPA 2003 s 222 (the old ICTA s 144A for those still using Old Testament references) on late reimbursement by employees of PAYE on 'notional payments'.
Section 222
Whether or not the employer has accounted...

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