8(1)The amount of the relief is equal to the difference between—U.K.
(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.