Corporation Tax Act 2009 section 1018

Calculation of relief if shares are neither restricted nor convertible

Section 1018 explains how to calculate the amount of corporation tax relief available to an employer when an employee acquires shares through an option, and those shares are neither restricted shares nor convertible shares.

  • Relief equals the market value of the shares at acquisition, minus any consideration given by any person for the option or the shares
  • Consideration does not include the employee's performance of employment duties or employee National Insurance contribution arrangements
  • Where consideration relates partly to the option or shares and partly to other matters, a just and reasonable apportionment must be made
  • The amount of relief calculated under this section may be further reduced under section 1020

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