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Corporate tax deductions for share plans

Corporate tax deductions for share plans

Consideration of some of the practical issues that can arise when claiming corporation tax deductions in respect of share incentive arrangements.

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Under CTA 2009 Part 12, a statutory deduction potentially applies to all forms of employee share awards, although different chapters of Part 12 apply to stand-alone share acquisitions and securities options. There is longstanding uncertainty about the correct taxing provision in ITEPA 2003 for restricted share units (RSU) style awards, which can have implications for claiming a statutory corporation tax deduction. With effect for share acquisitions on or after 6 April 2015, additional statutory deductions may be claimed for internationally mobile employees. Net settlement of an award can limit the available statutory deduction. Part 12 relief is limited to the acquisition of shares, so any other deductions, such as interest and administration costs, must be claimed under general principles.

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* First published in Tax Journal on 1 March 2019. Reproduced with permission.

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