Stephen Woodhouse

After studying law at Leicester University and a career in the City of London spanning 30 years Stephen joined Pett Franklin as the third partner in the team on 1st December 2013.

While practising in the City, Stephen trained at Slaughter and May working in their tax department for seven years after qualifying across a range of tax matters but particularly on employee share schemes. From there he joined Norton Rose to assist with building their employee share scheme practice. He joined Touche Ross (later, Deloitte LLP) in 1994 becoming a partner in 1999 until leaving Deloitte to join us on 1st December 2013.

Throughout his career, Stephen has advised on tax with particular emphasis on employee share schemes and related remuneration issues. He has advised on both domestic and international issues and become an acknowledged expert on employee benefit trusts in their many different guises, both as an adjunct to the operation of employee share schemes as through their wider use to deliver cash based benefits to senior employees, a vehicle to facilitate employee ownership and as part of the succession and exit planning for privately owned companies.

In addition, he has advised extensively on pension planning, particularly for plans to top up the benefits allowed under HMRC registered plans. This includes plans designed consistently with the requirements of the relevant legislation to permit the building up of pension benefits for senior executives in excess of the annual allowance for tax protected pension accrual and the lifetime allowance for tax protected benefits under UK registered plans. He believes that this will be an important area for focus in remuneration and benefits design as the lack of any index linking for registered plan limits mean that the real value of those benefits will erode over time.

As a leading adviser, Stephen speaks frequently at conferences and publishes in the tax press, being a regular contributor to Tolley's Tax Planning and a range of articles and other publications. He also co-authored a textbook on The Taxation of Pension Schemes and worked with the Goode Committee on Pension Law Reform.

Contributed to

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Employee ownership trusts

Practice notes

This Practice Note outlines the concept of an employee ownership trust (EOT) introduced by Finance Act 2014. The Practice Note summarises the main features of an EOT and the main tax reliefs which it provides.

Share Incentives

Employee shareholder shares—shares for rights [Archived]

Practice notes

This Practice Note examines the employee shareholder status (also known as shares for rights) pursuant to which, until December 2016, tax reliefs were offered to participants in return for surrendering various employment rights. The note examines the tax reliefs that were offered, the requirement to value the shares, the employment rights which had to be surrendered and the protection that was afforded to the employees who entered into this regime. Finally, the note examines the company law implications that arose in relation to the employee shareholder status, the required documentation and its use in practice. As of 1 December 2016, no new employee shareholder status arrangements can be entered into and still benefit from the tax-advantaged status. Any employee shareholder share arrangements implemented prior to this date remain unaffected. This document has been archived and is no longer maintained.

Share Incentives

Introduction to JSOPs

Practice notes

This Practice Note introduces the concept of joint share ownership plans (JSOPs). It details the commercial advantages of JSOPs and introduces the nature and structure of JSOP awards and their tax treatment.

Share Incentives

Joint share ownership plans—comparisons with other share scheme structures

Practice notes

This practice note seeks to compare jointly owned awards (JOAs) granted pursuant to jointly owned share plans (JSOPs) with unapproved share options, long-term incentive plans and growth/value shares. This Practice Note is written in conjunction with Stephen Woodhouse and William Franklin of Pett Franklin.

Share Incentives

JSOPs—adopting and granting awards

Practice notes

This Practice Note is a summary of the main steps that are required in order to establish and adopt a joint share ownership plan (JSOP) and grant awards pursuant to it. It examines the steps involved and the required documentation.

Share Incentives

JSOPs—funding the acquisition and terms of the plan

Practice notes

There are various different ways in which a trustee of an employee benefit trust (EBT) may be funded in order to acquire its interest in a jointly owned share acquired pursuant to a joint share ownership plan (JSOP). This practice note examines the various approaches to funding the trustee of the EBT and the consequences of each approach. It also considers the terms on which the respective joint interests are held, and outlines the current market norms in respect of such terms.

Share Incentives

JSOPs—tax treatment

Practice notes

There is no specific statutory regime setting out the tax treatment of jointly owned shares acquired pursuant to joint share ownership plans (JSOPs). Rather, the tax treatment follows on from the nature of the interests being created and the application of the tax legislation relating to employment related securities. This Practice Note summarises the tax treatment (including income tax, National Insurance contributions, capital gains tax, corporation tax and stamp duty) resulting from the acquisition of an employee’s interest in jointly owned shares, the subsequent realisation of value and the exercise of call options. This Practice Note is written in partnership with Stephen Woodhouse and William Franklin of Pett Franklin.

Share Incentives