Note: HMRC’s Employment Related Securities Bulletin No 27, issued on 4 April 2018, gave notice that EU State Aid approval for the EMI scheme expired on 6 April 2018. The Bulletin said the Government had been, and was, seeking fresh approval, but went on to say:

‘EMI share options granted in the period from 7 April 2018 until EU State Aid approval is received may not be eligible for the tax advantages presently afforded to option holders, and accordingly share options granted in that period as EMI share options may necessarily fall to be treated as non-tax advantaged employment-related securities options.

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