Corporation Tax Act 2009 section 1012

Reduction in amount of relief

Section 1012 requires a reduction in the amount of employee share acquisition relief where the employee's role relates partly to a qualifying business and partly to a non-qualifying business.

• This section applies where an employee's role spans both a qualifying business and a non-qualifying business (or part of a business)
• Relief must be reduced by a just and reasonable amount to reflect the dual nature of the employment
• The qualifying business must meet the conditions set out in section 1007(2) of the Corporation Tax Act 2009
• The reduction ensures that relief is only given in proportion to the extent the employment relates to the qualifying business