SCHEDULES
SCHEDULE 23Corporation tax relief for employee share acquisition
Part 2Award of shares
Amount of relief
8
1
The amount of the relief is equal to the difference between—
a
the market value of the shares at the time of the award, and
b
the total amount or value of any consideration given, by the recipient or another, in respect of the shares.
2
The consideration mentioned in sub-paragraph (1)(b) does not include the performance of any duties of, or in connection with, the employee’s employment with the employing company.
3
A just and reasonable apportionment shall be made for the purposes of this paragraph of any consideration given partly in respect of the shares and partly in respect of other matters.
4
If the award was made partly for the purposes of a business meeting the requirements of paragraph 3 (business must be within the charge to corporation tax) and partly for the purposes of a business in relation to which those requirements are not met, the amount of the relief shall be reduced to such extent as is just and reasonable.