OECD The Taxation of Employee Stock Options
Titel:OECD The Taxation of Employee Stock Options
Omfång:170 sid.

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Table of contents

Chapter 1 Tax Neutrality
1. Introduction
2. The case of certainty with only corporate taxes
3. Introducing personal level taxation
4. Introducing uncertainty
5. Introducing possible different productivity
6. Introducing employees’ risk aversion
7. Summary
Annex 1.A.1: The Algebra of Neutrality

Chapter 2 Effective Tax Rates
1. Introduction
2. Qualitative description of the tax treatments
2.1 Concessionary schemes
2.2 Other incentive pay schemes
2.3 Tax Treatment of Schemes
3. Tax wedges on stock options and incentive pay schemes: the calculation methodology and results
3.1 The issue of disallowing labour costs
3.2 Introducing personal income tax and employee social security contributions
3.3 Introducing the time lag for stock options
3.4 The results of the calculations
4. Comparison between stock options and ordinary salary
5. Comparison between stock options and ordinary salary for higher levels of income

Chapter 3 Cross-Border Income Tax Issues
1. Introduction
2. Background on ESOPs
3. Issues related to the employee'
3.1 Timing mismatch in taxing the employment benefit
3.2 Distinguishing employment income from capital gains
3.3 Difficulty in determining to which services the option relates
3.4 Employment services that are provided in more than one State
3.5 Multiple residence taxation
3.6 Compliance issues
3.7 Alienation of stock-options as a result of a merger or acquisition and replacement of options
3.8 Valuation issues
3.9 The granting of stock-options to members of a board of directors
4. Issues related to the employer
4.1 Deductibility of the costs of ESOPs
4.2 Remuneration “borne by” a permanent establishment
Annex 3.1 Graphical Illustration
Annex 3.2 Changes to the OECD Model Tax Convention

Chapter 4 Impact on Transfer Pricing
1. Introduction – Scope of the study
1.1 Introduction
1.2 Scope of the study
2. Situation I: An enterprise grants stock options to employees of an associated enterprise that is resident in another tax jurisdiction.
2.1 TOPCO Example: The “Non-Dilutive stock option plan”
2.2 Variant to TOPCO example: Dilutive plans
2.3 Preliminary conclusion to Situation I
3. Situation II
3.1 The impact of stock options on controlled transactions (other than transactions with respect to stock options) in which the employees benefiting from stock options are involved
3.2. The impact of stock options on comparability analysis when employee remuneration of the tested party or the comparables is materially impacted by stock options. determining a comparability adjustment
3.3 Interaction between domestic rules and tax treaties
3.4 Preliminary conclusion to Situation II
4. Situation III: The impact of stock options on Cost Contribution Arrangements (CCAs)
4.1 Example
4.2. Should stock options be included in the valuation of the contributions of participants to a CCA?
4.3 Where stock options are included in the valuation of participants’ contributions to a CCA, what should the valuation principles be?
4.4 Interaction between treaty rules and domestic rules
4.5 Preliminary conclusion to Situation III
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