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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

HM Revenue & Customs
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Schedule 4 Company Share Option Plan (CSOP): Shares to be used: Close company

Close Company has the meaning given by Section 989 of ITA 2007. Guidance on these sections is at CTM60100.

A company is not a close company for the purposes of this section if it is subject to an employee-ownership trust (within the meaning of paragraph 27(4) – (6) of Schedule 2 ITEPA).

An overseas company which is wholly owned by an overseas Government would not be considered to be a close company if it were resident in the UK. But if the overseas Government is only a majority shareholder, and does not own the whole of the share capital of the company in question, the advice of the ESSU Operations Manager should be sought on whether it would be close.