Global Share Plans with Chris Fallon

Employee share plans are effective tools for fostering alignment and engagement within organizations, but managing them across multiple jurisdictions presents unique challenges. From navigating tax regulations and cultural perceptions of equity to addressing administrative complexity, implementing these plans requires strategic planning and adaptability.

This podcast explores insights shared by Chris Fallon, Legal Director at Tapestry Compliance, highlighting key trends such as broader employee participation, the rise of purchase-and-match models, and the preference for simplicity and transparency. It also delves into tax complexities, regional regulatory variations, and balancing global consistency with local customization.

By prioritizing stakeholder collaboration, clear communication, and regular plan evaluation, companies can design impactful global share plans that drive long-term success while navigating a highly complex landscape.

For more information
Check our website: https://www.optioincentives.com/stock-n-roll
Follow Optio on LinkedIn: https://www.linkedin.com/company/optio-incentives
Read the blog: https://www.optioincentives.com/resource-hub/navigating-global-employee-share-plans

Join Stock 'N Roll with Christoffer Herheim, CEO and co-founder of Optio, as we break down what works—and what doesn’t—in equity compensation, with insights you can act on.

Chapters

• 0:00 Introduction to Stock n Roll Podcast
• 0:58 Meet Chris Fallon: Legal Director at Tapestry Compliance
• 2:33 Understanding Global Share Plans
• 6:29 Navigating Taxation in Global Share Plans
• 16:37 Challenges and Trends in Global Share Plans
• 31:17 Tax Reporting and Administration
• 33:53 Conclusion and future episodes

Transcript

  Hello, and welcome to Stuck and Roll, the podcast where we dive deep into the world of equity compensation. In this episode, we're thrilled to have Chris Fallon joining us.  Today, we'll explore the fascinating yet complex world of global share plans, from understanding key instruments to navigating the multi layered taxation landscape.

We will unpack the challenges and best practices of administering plans across borders. Chris will also share insights on adapting to regional tax trends, avoiding common pitfalls, and balancing consistency with localization. 

We are here with the Library of Global Tax. Chris Fallon, uh, it's a pleasure having you here. Um, and I won't steal your thunder on your, your introduction. Uh, I'll leave it over to you. Who, who are you and, uh, and why are you here? Yeah. Thank you very much. It was a pleasure to speak to you and thank you very much for the opportunity.

Um.  So, I'm Chris. I'm a legal director at Tapestry Compliance.  I've got just over 25 years of experience working in the incentives industry. I started as a paralegal in 1999 at EY in October 1999, the last millennium. And, um, I've been at Tapestry now for very nearly nine years. Uh, and I've been a legal director now for four of them and was appointed to the board of directors about the same time when Tapestry became employee owned.

So, um, we're a, a small boutique legal advisory firm that specializes just in the provision of incentives and compliance, uh, advice and information for large global companies that want to roll out their share plans worldwide. And, um,  uh, as I say, we've, we, we do all aspects of incentives, both cash awards with share awards, but all ways in which the companies have to address the legal regulatory and tax issues of implementing and operating their plans in.

in whichever jurisdiction they want to operate in. I remember the first time I met with Tapestry, I guess it's like five years ago or so, where I was really impressed by just getting out these ready, great PDFs that was relevant to the clients with their, to, or their instrument types and these countries.

And it was a super, super valuable thing for, uh, for us and our clients back then, at least. So yeah, that is great. And, um, so what we've got is a, we, we, we drive our, the work we provide through, um, a database called the ONTAP database. Um, so, uh, that contains the information necessary for companies to decide whether and how to roll out plans in very nearly 160 countries.

And it looks at the different securities types. Uh, the, the, the structure of the awards be an option or a free share award or, or a cash based award. And, uh, it looks at the, the legal, uh, the tax and the regulatory, um, information necessary to, for companies to carry out the due diligence or the feasibility that they need to, to, uh, conduct to work out whether the plan works in a particular country or not. 

Oh, yeah, definitely. It's, uh, very much needed. Um,  today's topic is.  Very wide. Yes. Um, what we want to do is, is to give the listeners a bit of,  when starting to navigate in, okay, we have a broad based plan or we have, at least we have employees globally. Yeah. And how to kind of incorporate tax thinking into this, like do's and don'ts, types, some countries.

So we want to kind of give an intro lesson in a way to, to, to everyone's listening. So, um, if I'm starting off then and say the kind of, if you would.  give a very, very high level, um, overview of what's the instrument types you see from your point of view in global programs. Okay. Uh,  the starting point is companies wish to ensure an alignment between their employees and their shareholders.

Being an employee owner of businesses is a generally regarded as a good thing. And some countries have got that message more so than others. Yeah. And we'll talk about that in a bit. Um, but generally speaking, there's, there are various rules and regulations in play, which either help or hinder employees getting a hold of shares.

And, um, that's together with the, perhaps the strategic aims of the company will drive the instrument choice. Um, for example, um, do you as a company wish to ensure that everybody in your, uh, who works for your business want to have a share or get a share? So that might lead you to a free share award, um, or do you want employees to feel like they're, they're buying into the success of the business?

So that might generate some sort of participation or contributory sorts of planning. Is it a share purchase arrangement or is it an option type arrangement like the share saving in the UK? And questions like that. When  looked through the lens of what your strategic aim is going to be, will lend you or lead you rather to an answer in terms of what sort of plan structure you're going to have and then once you've started to look at what plan structure you've got and where your plan is going to be.

So, for example, it could be China, it could be France, it could be the UK, uh, the rules in those countries will lead you to, um, realize whether it's easy or hard, really, to run that plan in those countries. And it might be that it's just too hard, it's just too expensive to run the plan in such and such a country, because there may be particular exchange controls or maybe securities rules, and that might lead you so, right, it's just too hard to give shares, we'll just give cash, or we may structure the award as a bonus.

So all of these issues, and all of these These aspects of plan design will lead you to determine what is the best and the right sort of instrument that you should be placing under the award. Yeah, no good. Uh, agree. Um, do you see any kind of, cause of course,  There are also in our world, some trends, there's like ESG is now, there's like, do you see any kind of, uh, the last three, four, five years, is it like kind of kind of leaning more towards options or investment programs or performance plans, or  are there any lines you could draw here?

That's, that's really good question. So. To take a step back, one of the, the key drivers, I think, in the global share plans world has been the, the infrastructure and the framework in the UK.  Um, a lot of the global share plans that we have seen over the last 10, 20 years have been driven in part by the UK and the U S classic all employee share plan, the savers you were in plan or the share incentive plan.

And, uh, That's because those are the two of the sort of mother territories where the, the governments of the day have recognized that employee ownership is a good thing. Yeah. And they've created the, uh, the easements and the, the facilities to enable employee ownership. And the large companies in those countries have.

adopted and incorporated those share plans and then slowly rolled those out worldwide. So  there's an awful lot of global share sale plans out there. There's a lot of, uh, share purchase and buy one, get one free type plans, which are very similar to the UK share incentive plan. And so that's, that's the sort of the, the, the, the trend setters for the global industry.

Um, and so  Over time, those plans have been rolled out around the world and to one degree or another, they've either been easy to operate or not. 

And I've seen certainly, and I think tapestry would take the view that the option is less common as the primary mechanism of having a global share plan. And we are now seeing far more interest in things like global purchase and match arrangements. Yeah. So they are. They're not the only game in town, but they are certainly the more popular form of global share plan.

And that's been the case now for a couple of years. And I think also taking into account things like, um, the, the move to accounting for the, uh, the cost of share based payments, which has now been in place for about 15 years. I've probably got the date completely wrong, but since about 2007, Five ish? Yeah.

Um,  companies have had to recognize the cost of the, uh, the stock that they've been giving to employees. And that has, in part, driven a move away from options, which used to be the classic form of incentive, uh, both at the executive level, but also at the employee level. Yeah. And so that's, that's been another factor of being, driving that move away from the option.

And moving to, uh, a more straightforward, uniform. Uh, purchase and match arrangement where everybody buys shares at the same time, everybody vests at the same time, and you don't have the, uh, the sort of spotty or sporadic purchases or exercises of shares that an option arrangement might generate. Just easier to administrate, uh, when you've got  20, 30, 40 countries to administer your plan in.

Yeah. And I think, I think also one thing that we see a bit is that even private equity companies that have been, or private equity backed companies that have been doing this, uh, you know, smaller MIPS with two, three percent of their people is also going broader on similar schemes as well. So I think it's a, it's a, as far as we see, at least it's a, it's a trend to going broader and involving more people.

Uh, and of course that's a, that is the thing that, um, yeah, we'll,  we'll also spread throughout, uh, all sorts of, uh, companies. If you're a small, or if you're a listed big, or if you are a private equity company. So it's, uh, yeah, absolutely. Yeah.  Um, if we. If we are going on to like the tax part, um, that is, um,  if we start off with like, how are things taxed generally, just to give an overview, and then we could rather dive into like the, the qualified plans.

Yeah. And then those things. So as a very, very rough rule of thumb, the principle should be at the time your rights to create or right to acquire a share in the future is created. Uh, there shouldn't be a charge to tax at that time, the time of grant Should be a tax exempt point in time. It is a time at which you become entitled to receive the shares.

Um, that should be the taxable point. Uh, and that is generally subject to income tax. Yeah. And it's quite commonly subject to some sort of withholding arrangement as well. Mm. And there's typically social security going to be charged at that time. So, at the time the right is created, no tax. Yeah. At the time you are due to get the share, so vesting.

Yeah. Um, sometimes it's delivery. Mm. But more often than not, a rough rule. Vesting is the point at which tax arises and there's usually withholding and there's quite often social security to pay as well.  And that is kind of pretty much in most of the jurisdiction.  Yeah, and you work backwards from that principle really.

So at Papistry, when we're carrying out due diligence for clients, we usually start with an assumption, which is,  Creation of the, the grants of the award or the entry into the plan, no charge to tax and, uh, uh, the, the purchase of the shares, uh, if it's at a discount that they should be taxed to pay there because there'll be a difference between the price you paid and the price it's worth, or if there's a vesting, so a matching share award, uh, vests and it's a free share, the value of that share will be subject to, uh, some sort of employment income tax charge and social security.

at the time you are due to get that share. Yeah. And that's, that is the principle. And, um, as you say, in some jurisdictions, uh, there may be a different tax treatment and you, and you, you, you vary away from that on a country by country basis when you're carrying out your due diligence. Yeah.  And, um,  are there any.

Kind of, let's say someone come to you, they want help on like, okay, this is the  10 countries that we have employees in. Yeah. Is it common then to do a different program per country because of that there is different kind of pre qualified programs? Yeah. Or do you typically do one, uh, UK based and that's what others are and then they may get, uh, more tax benefits or not?

Yeah. Okay. That's a really good question. And there's, there's no definitive answer to this because there's all sorts of factors that will lead you to where you want it, where you ultimately going to end up. One of them is cost. Another one is time. Another one is just resources. Um, and also might be strategic aims as well.

Some companies, regardless of whether there might be a particular tax qualified route, right? Uh, available. Yeah. And given the tax savings in some of these, uh, jurisdictions, some of these plans can be quite enormous and there's sufficient employees, but it, it,  The strategic aim might be, everybody has the same right of participation in the plan, and the plan is the same, whatever you wish to implement it.

It's a one size fits all.  And then, overlaid against that, you're going to have things like the UK, the US, France, Israel, where there are countries where there's a particular tax qualification, or tax exempt, or tax relieved approach, which might make it, We're thinking about, um, certainly in the UK, as I say that that's one of the, uh, the trendsetters of, uh, employee ownership, I think.

And as a result, we've got quite a complex infrastructure of, of tax advantage plans, um, which are commonly understood by the population. France is another one and, uh, the local population may demand it. So, right.  The other competitive firms we could work at, these plans are available. Can we have one? And so you will start to see some companies tailoring the approach in some countries.

Um, and it becomes a question of how far do you want to deviate from the one size fits all approach that is  Yeah. And you may wish to start tailoring it and, and varying it for particular countries in order to achieve a particular tax outcome. And it may be that if the tax savings are so great, both for the employee, but also for the employer, it might be worth pursuing because you can get, for example, in the UK, the share incentive plan.

It doesn't take a huge proportion of a relatively small workforce to make the plan worth paying, paying for itself. But yeah. Cause I think like. Obviously, you touched upon it like if you  have been, if you are working in a company that have these pre qualified plans that is super beneficial for you and someone, some company from abroad try to recruit you and you're not able to kind of cater for those setups or even put you in a tax, uh, call it like a trap,  which sometimes also happen.

It's quite hard to use this thing as a, as a, um,  As a recruitment tool at least and and then I think you kind of need to have that part You've got to be aware of it. Definitely if you if I wouldn't know not to make it too difficult for you But if you were to to kind of from your gut feel to 10 percent 50 percent or 80 percent  Do anything  Local versus one.

Oh gosh, um,  that's a really good question. What proportion of Tapestry's clients, um,  I would say it's somewhere between 50 and 80. So I'd say more do than do not.  I think a number of them will,  because again, just to go back to the basics, when you're thinking about running a global plan and you've got multiple jurisdictions to do it.

Hmm.  Oftentimes, you've not done it before, and you don't quite know the cost and the time of doing it. The one size fits all approach is certainly the ground floor approach. And it may be, as the plan gets more popular and gets more understood, and you, as the issuer, have got more familiar with its operation, you feel more comfortable stepping outside the standardized terms. 

Um, and I think certainly that the longer these plans are in place, the more appetite there is to go, well, how can we push participation, uh, to get ourselves from like the 10, the 20 or the 30 percent participation, all the way up to higher numbers. And tax qualification is one of those ways of doing that.

Yeah. And it sounds like a smart way of doing it as well. Instead of trying to solve all countries at once and you deploy some sort of a monster that it can't really handle. It's, you go with the plan. The base? Yeah. And you rather build up when you see what's the lowest hanging fruits versus where you have more people and then you can rather control how much extra burden and, and, and the challenges that it, uh, end up in.

Yeah, absolutely. Um, when it comes to, to kind of different jurisdictions, um,  what are the, from the UK perspective now,  what are the most challenging, uh, Countries you see, which is common to have in reason from a UK company perspective. So  to go back to my earlier point about the certain countries got the idea that employee ownership is a good thing sooner rather than others.

And I think it's reasonably safe to say that sort of Western Europe and America, um, and, uh, are the key drivers of the employee ownership program and the UK would be the, perhaps maybe the.  The focal point, um, but the areas around the world haven't  got the memo now. Um,  and in particular, I would say Southeast Asia is, is, is coming up to speed.

Um, and so we are seeing, uh, quite a lot of, um, Variability in terms of the local understanding, both at the employee level, but also in terms of the issuer level. And also probably most importantly, the regulatory  side of things where there are countries where the regulator just doesn't quite understand  what the point of an employee ownership man is.

Um, and, and as a result, you don't have the same sort of, um, facilities like we have in the UK or in America where  The local laws allow and en enable employee ownership. Yeah. So  countries like China are, are problematic, um, but less so than they used to be because companies are increasingly pushing the global share plan.

Yeah. And so regulators and administrators, um, are more familiar with what these plans are. And so what used to take a long time, a lot of money to get in place in say, just focus on China. Mm. Is, is still.  Time consuming expensive, but much less so than it used to be. But there are other countries say in Vietnam, uh, which is probably the hardest country, I think outside of North Korea to put an employee out of your pannier.

Um, where. Um, again, you're coming up against, uh, a, a, an institutional, um, difficulty in understanding why, uh, we're trying to do what we're doing in that particular country. So Southeast Asia is one, um, and it's sporadic really. Some countries are easier than others. Japan is certainly on the way up. South Korea seems to be moving forwards and backwards in terms of, uh, how easy it is to operate a share plan.

Um, um, and, but also Africa is a, it's a very difficult, um, Uh, regions puts, uh, any sort of global plan in  of any type of share based award. It doesn't really matter whether you're looking at contributory plan or just a free share plan. The local exchange, uh, control rules, the local securities rules in quite a few African countries will make it quite difficult to get your global share plan running there.

Um, South America is, is patchy. Um, and, but these are all regions where the, the good news of employee ownership is starting to be spread, but there's still a degree of, um,  institutional inertia that you've got to work with. Politicians in a, in a country does not really recognize the value of it. Then it's very hard to get.

The laws and the regulatory and the tax environment to work. Absolutely. Because we've, we've had 50 years of employee ownership being a good thing in the UK. So it's, it's here to stay in the UK and there's lots of evidence  to demonstrate it, whereas it's just less familiar in other countries. Italy, France, Spain, are those okay?

They  all have quirks. Yeah. There are aspects of the local laws and rules, which could be. You have to be mindful of, it's part of the due diligence process, but none of them are, um, certainly none of the European countries, I would say, are particularly challenging. Um, I, I'm sure they'll have colleagues listening to this podcast before we pull in there.

But, um, in, in the grand scheme of things, if you compare Italy to Vietnam, there's no comparison. You can run most types of share planning in Italy or France. There may be valuation rules you've got to be mindful of, there may be communication or translation requirements. Um, there may be consultation requirements.

They're all  surmountable with time and money. Um, as I say, other countries are not. It sometimes feel like there's a cliff face that you simply can't go. I think that's an important thing. You'll always find the quirks when you go in there. You find it hard to cope with the tax box things in Germany. Or it may be hard to move shares out of Italy because you want to have them on a trust in New Jersey.

And you have these things, but in Relation to these other countries. It's still  achievable. It's achievable. Yeah. Yeah. No, but I think that's, uh, that sounds, uh,  yeah. Uh, I remember back in time when it was, uh, when I started with working with these, uh, these type of plans, it was always like, if you do Asia.

Synthetic. That was always  how it started. And I think that's changed a bit. Definitely. Um, tapestry, we've got, uh, a large and growing Japanese practice. And, um, there's been a, a change in the taxation of plans at the company, the issuer level, uh, which has really changed the attitude and the aptitude of companies in Japan to, uh, to think about employee ownership, uh, uh, um, from a global basis.

And we've seen an explosion of interest of employee ownership plans in, uh, in Japan. And I think there's, as you said, there's a long way to go, um, because the, the, the local government and the regulators are still catching up.  But the same could be said in the UK, for example, we're still behind the curve when it comes to worker types. 

So it's constantly evolving, um,  position that we're in at the moment. And, um,  some countries have got further to go than others. Yeah.  Do you see any kind of, um, if you, uh, if you have a bad, uh, share plan tax nightmare, like do don't do this in this country, this is the absolute three things you need to avoid. 

Do you have any kind of top of mind things that like, this is  the minefield of don't do this. Don't do it. Um, 

it's, it's.  Not quite the right answer. I'll probably answer this in over a couple of minutes. The thing that gives me fear is when I have a client who tells me about an existing plan. And it's been in place for a couple of years. And they've been making grants in jurisdictions like California in America.

Um, it's always California, um, and there are rules in California that say if you grant uh, to over 35 employees, um, there's all sorts of additional, um, local, uh, securities laws that need to be complied with. And  so you, it always gives you the fear, um, when, uh, you are coming into an existing plan that might not necessarily have had the full DD carried out against it.

In terms of tax.  It is still very surprising how, and again, to go back to my earlier point, as a general rule of thumb, getting the share should be income tax, and it's probably going to be subject to withholding.  That's, that's the starting point. It's surprising how many very large companies haven't been aware of that.

And the failure to withhold is, um,  can be enormous in terms of the likelihood of liabilities. Because often times it goes back several years worth of failures. Mm. So that can be a, uh, probably my number one.  issue to avoid, um, is think about the withholding with reporting. Securities laws are always problematic.

They always need to be thought about, but the tax will be the thing that will  cost you the most money if you fail to withhold. I think also what we've seen a couple of times is that when there's one country that have  a way of getting onto capital gains tax instead of income tax,  because of the, here you can do it like this or this or this, and you just do that for your global employees and you don't really.

understand or address or inform that this will be in your country taxed as income tax, and it may be at a point of time where you get some shares, but you can't really sell some shares. Yes. And then you suddenly get like this huge tax bills in your mailbox and then shit, what do I do with this? I can't sell any shares.

I need to sell my house, like that part as well. I think like it's, uh, it's, um, uh, you know, unfortunately, I think that, uh, Well, things,  yeah, failure to, to understand how you're supposed to administer the plan, failure to communicate that to employees as well. Yeah. These can be absolutely lethal. They affect more of what is supposed to be an incentive reduction arrangement.

And if you get that wrong, you will kill the plan. 100%. I think that's, uh,  oh, there's, there's, um, Yeah. Yeah. Yeah, no, I shouldn't, uh, talk about it, because then someone may understand which, which, uh, scenarios I, I, I talk about, but yeah. Um,  in terms of tax Are there any trends there? Do we see like any, any movements or, or any, any things that we, are there hope for the future?

Uh,  well, the, the, the roof principle  is the, uh, the value of the share that you get, um, will be income taxable. Yeah. That's anything you pay for it. Yeah. And any growth in the value will be subject to, uh, typically some form of capital taxes. And again, as well as employee ownership being a good thing. 

Ownership and long term ownership of capital assets is also seen as a good thing. So typically speaking, you will see lower rates of tax whilst you hold the share and come to sell the share. So that, that's, those are the very broad principles. Um, in terms of longer term trends, I think there's been a bit of a race to the bottom at the issuer level for, from a corporation tax perspective.

So the. Um, the, the tax relief that's available therefore in relation to the acquisition of employee shares may be smaller than it used to be simply because the rates of tax are now historically quite low in a number of countries. Um, I know the UK has put its tax rate up recently, but  over the last few years, I would say that the tax relief, um, that's available to companies when they, they're running share plans has reduced, um, the.

Um, the reliefs that are available seem to be slowly increasing, uh, Germany have just increased theirs. I want to say just a couple of years ago now, uh, have increased the relief that's potentially available to certain types of tax qualified award in Germany. Um, the UK has historically been quite generous, um, it's probably due an overhaul though.

Um, so it's, it, there's increasing awareness, I think, of the good news of employee share ownership. And so I think. To the extent you can call it a trend, I'd say maybe the tax position is getting slightly better. Yeah. Yeah. Well, that's good. That's, uh,  that is very good. If, um, this is kind of my, my, uh, call it last question for this episode.

Um, it's, it's not a, not an easy one, but, uh, if we imagine a world now where you are the CEO and you also have control of all the owners, so you are in a world where you can do whatever you want and you have 500 employees in your company. Let's say you. Are within,  it's a tech company.  Um, you have employees, quite a lot of employees spread in both UK, since you're a UK company.

So most are here, but, uh, you also have US, uh, you have Spain, Germany, Sweden, and Italy.  Uh, what do you want to drive is basically, uh, you want to make the company grow for a five year period. And then you can decide if it's like, what's, what do you want to,  what's your thoughts around and what do you think you would have ended up with as a plan?

I know that it takes more than two minutes to design a plan, but, uh, but just to kind of, um, Yeah, this is the exam question. Well, it, it depends whether, the first question is, are you listed or not? Are you looking at listing? Are you a private company? So what's your ownership? I would say you are listed. So we are listed.

Okay. Well, that's half the answer. Yeah. Um, but you, but you, but you, you can control the voters. So I can control. So I, I think I was,  in which case we're listed, we've got the resources available. Uh, we've got a friendly administrator, administrator on board. Um, so we're looking at some sort of share based plan.

Um, since we have a U S presence, I would say some sort of stock purchase arrangement for the American employees. Um, Um, maybe a variation of that, um, for the other employees in the other jurisdictions, but I would have thought the U. S. plan will probably be the, um,  foundation block around which the, the, the feasibility of the plan design should be carried out.

Um, it's, it's a type of plan that is permitted in the jurisdictions you just mentioned. Um, the, the U. S. employees would probably demand it. Mm. Although, uh, did you say France were one of the, uh,  Uh, no, but we can add France as well. It makes it even harder. But then you get to countries like France where there's a particular form of tax qualified, um, share, um, share ownership opportunity, uh, which was created by Emmanuel Macron when he was the finance minister.

And that's built around conditional share rights. It's all free share rights. And, um, there is often, particularly at the, the senior or, or executive levels in French subsidiaries, a, a quite strong demand for that type of plan structure to be put in place. And that goes back to your point earlier about, do you go for a local variation or do you go for one size fits all?

So.  Ultimately it depends on how much cash I've got to spend  putting this plan in place. Um, I could if I wanted to, uh, spend an awful lot of money and have a gold standard global plan which is tailored to tax efficiency in each of the jurisdictions you've mentioned. Um,  And, and, and since tapestry is employee owned, um, I would say I'd have to be, uh, guided by that as a principle.

So what's the most savings I can get from my employees? Assuming money's no object, I'll have a UK tax advantage plan, please. I'll have a section four, two, three plan in America. I'll have a Macron plan. In France, I'll get the tax easement in Spain. Yeah,  you get everyone, yeah. And while you were speaking there, I kind of came, yeah, I just have one final question after the final one.

Like, how and to what extent do you see, like, the tax reporting is being done, like, because there's people getting shares here, what's your Uh, how do people do it? Uh, how, what, what is the company's responsibility? What is, uh, what do the, the employees ends up doing? What do the administrators do? Just like  your feel on, on that part, because obviously like you give shares and you put people in a tax position one way or another.

Yep. Um, just to give like the listeners a bit of like how to, to cope with those things. So when you're putting a plan in place, um, the, the gold standard approach I would say would be to bring all your key stakeholders into play, uh, be it both internally. So your company secretarial team, your HR team, uh, you may have a finance department, uh, you may have tax specialists or communication specialists, but you also have an administrator uh, certainly at the global share plan level and you should bring everybody together.

Um, they want to work out who's responsible for what and to make absolutely clear where the lines of reporting the communication are. Um,  so  when, That responsibility is, is determined, be it an individual or a company reporting requirement.  The relevant person knows that they've got to deal with it, or, or at least communicate it, probably.

Um,  in terms of, uh, the reporting itself, who actually does it, the,  the acquisition of shares, be it the vesting of a share award or the exercise of an option. It's usually done by the company or together with its payroll administrator, um, the, the administrator will have extensive involvement because there'll be the ones delivering and holding shares on behalf of the employees.

So it'll be a, a sort of a,  a potentially a, a tripartite arrangement between the payroll people, the company and the administrator when it comes to share sales. So on the other side of the, of the. The curtain. Um, that is typically, not universally, but that is typically the responsibility of the participant.

Yeah. And, and it, and again, that comes down to whether you're just going to let participants fend for themselves, uh, whether you're going to give them guidance or communication, uh, or education in terms of how to manage the process, or whether you're going to spend even more money and resource and allow your administrator or another third party to come in and provide, uh, uh,  assistance and information in that process. 

But the, the acquisition of the share is, is the payroll event. The sale of the share is usually the individual reporting event. Yeah. And it becomes a question of how you resource those.  No, super, super insightful.  I think that was, uh, my questions for, uh, for this episode. I think it's, uh, yeah.  Thanks a lot for bringing so much info into this and, uh, yeah,  I hear that by the listeners.

Yeah. And I think, I think I'll, I'll, uh, also, uh, try my best to get you onto another podcast, probably dive a bit into more UK specific stuff as well. Cause I think this is, uh, yeah, we could have made 10 out of this. I think so. Thank you. Yeah. So great. Thank you ever so much.