| Some people are not aware that if they receive | | | | 1997. The law only applies to "ESS interests" issued by |
| shares in a company for work they are doing (either | | | | companies. |
| as an employee or otherwise) that the receipt of | | | | It is still the case, as a general statement, that the |
| these shares can be income on which tax is payable. I | | | | discount (referred to above) is subject to tax. |
| have noticed that this incorrect notion is more | | | | However, the timing of when the discount will be taxed |
| prevalent in the small business community. This is | | | | and the amount of the discount that can be taxed is |
| probably because the issuing of shares is a "paper" | | | | determined by the type of employee share scheme. |
| transaction that may not require any money to change | | | | Depending on whether a number of conditions have |
| hands. The value of the shares does not immediately | | | | been met, up to $1,000 of the discount can be exempt |
| show up in anyone's bank account. | | | | from tax in the hands of the employee. Also, the |
| For many years the Australian taxation legislation has | | | | employer can get a tax deduction up to this amount in |
| had specific provisions that deal with the taxation of | | | | relation to each employee. |
| shares, or rights to shares, whether those shares or | | | | It is also possible for the taxing point to be deferred. |
| rights have been received in an employment context | | | | Again, a number of conditions need to be met for this |
| or in the context of the provision of services. Normally | | | | to be applicable. The employee share scheme rules |
| benefits are taxed under the Australian fringe benefits | | | | discussed above do not apply if an "ESS interest" |
| tax law. Employee share schemes are an exception | | | | qualifies for deferred taxation. Further, the employer |
| to that general rule. | | | | does not receive a tax deduction. |
| Broadly, what the law tries to do is tax the "discount" | | | | The policy behind the new provisions is that low and |
| on the issue of the shares or the rights. This means | | | | middle income earners should benefit from some tax |
| the difference (if any) between the market value of | | | | concession if they are offered shares in their employer |
| the shares or rights and what the recipient has to pay | | | | at a discount. If an employee's adjusted taxable |
| for those shares or rights. For example, a person | | | | income exceeds $180,000, the tax exemption of up to |
| receives 1,000 shares in his or her employer's | | | | $1,000 is not applicable. The new law says that one of |
| company and they have a market value of $5,000. | | | | its objectives is to increase the extent to which the |
| The person pays $2,000 for these. The difference | | | | interests of employees are aligned with those of their |
| between these two amounts ($3,000) is assessable | | | | employers, by providing a tax concession to |
| income, except if certain concessions apply. It should | | | | encourage lower and middle income earners to |
| be noted that in this situation the person has not | | | | acquire shares under employee share schemes. |
| received any cash that could assist with funding the | | | | One of the problems for the Australian Taxation |
| person's tax bill on the income. | | | | Office under the former law was knowing whether a |
| The rules in the Australian tax law that relate to the | | | | person had received any benefits from an employee |
| taxation of employee share schemes have been | | | | share scheme. Under the new law, employers will be |
| changed with effect from 1 July 2009. They have | | | | required to report to the Commissioner of Taxation |
| been completely re-written and there are some | | | | certain information to enable the Commissioner to |
| important changes to the way the law operates when | | | | ensure that the employee share scheme rules are |
| compared to the former law. The new law is found in | | | | being complied with. |
| Division 83A of The Income Tax Assessment Act | | | | |