So called “fettered payment” arrangements are now the focus of a new HMRC anti-avoidance spotlight. These structures typically involve a sum being paid by employers to employees on the condition that the sum is used to subscribe for shares in the employer, and such shares are then paid up in part only, leaving the balance of the sum available to the employee.  

See for more details: http://www.hmrc.gov.uk/avoidance/spotlights.htm