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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): Supplementary and defined terms: Retirement as a 'good leaver'

There is no statutory definition of retirement therefore the natural meaning of retirement is to apply. HMRC will not automatically apply meanings used for other tax purposes. For Schedule 2 SIP purposes, where a company has a retirement policy or practice, companies should determine whether termination of employment constitutes retirement in accordance with their retirement policies and practices, where it does not have a retirement policy and it is considering retirement for the purposes of Schedule 2 SIP participants it must be applied consistently for all of their employees. A cessation of employment should not be treated as retirement solely for the purpose of gaining tax advantages.

HMRC will not give rulings and does not expect retirement to be defined in the Plan rules.