The key points to consider for employment tax advisers can be summarised as follows:

• The Private Intermittent Securities and Capital Exchange System (PISCES), a new type of stock market, will facilitate secondary trading of private company shares on an intermittent basis. HM Treasury (HMT) will lay secondary legislation in May 2025 to implement PISCES.
• Trading on PISCES is likely to begin later in 2025.  
• Where shares have been acquired by reason of employment they will be Employment Related Securities (ERS) – this is not impacted by any listing on PISCES
• Shares which are traded on PISCES or acquired in the context of a listing/imminent listing will be treated as “readily convertible assets” for tax purposes.
• Therefore any income tax charges arising under Part 7 ITEPA will be subject to PAYE and such earnings will be subject to National Insurance Contributions (seek advice if the shares in question were listed on PISCES but are no longer traded at the time of the tax point).
• Listing on PISCES will not prevent tax advantaged option exercises under an EMI or CSOP.
• However amending existing options to allow exercise on a PISCES listing, or using discretions already in the options will result in the loss of tax free exercise of options. Exercise on a PISCES listing must be enshrined in the option from day one. 
• The valuation of a PISCES listed share on a transfer of ownership is broadly the amount paid. However in the absence of an arm’s length sale and purchase it can be complex to determine the value for tax purposes and no advance clearance is available from HMRC so I recommend consulting a specialist valuer.

For a full commentary on this topic please see Taxation of Employments, which is due to be updated later this year.
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