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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

HM Revenue & Customs
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Schedule 2 share incentive plan (SIP): General requirements: No loan arrangements

A Schedule 2 SIP must not provide for or be associated in any way with loan arrangements under which employees borrow money from their employer in order to take part (paragraph 12).  “Arrangements” includes any scheme, agreement, undertaking or understanding, whether or not legally enforceable (paragraph 12(3)).