Income Tax (Earnings and Pensions) Act 2003 section 35ZA

Non-UK company reorganisation arrangements

Section 35ZA defines what counts as a "non-UK company reorganisation arrangement" for the purposes of the Company Share Option Plan (CSOP) code.

  • A non-UK company reorganisation arrangement is one made under the law of a territory outside the United Kingdom in relation to a company
  • The arrangement must restructure the company's share capital by consolidating shares of different classes, dividing shares into different classes, or both
  • The arrangement must be approved by a resolution of the company's members
  • The resolution is only valid if members voting in favour represent more than 50% of the total voting rights of all members entitled to vote

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.