Corporation Tax Act 2009 section 1025

Additional relief available if shares acquired are restricted shares

Section 1025 sets out the conditions under which an employing company can claim additional corporation tax relief when employees have acquired restricted shares and a subsequent chargeable event occurs or the employee dies.

• Additional relief applies where an employing company already qualified for relief under Chapter 2 or 3 on an acquisition of restricted shares, and a subsequent chargeable event occurs or the employee dies — even if the original relief amount was nil
• The relief is given to the employing company, and the amount and timing depend on whether the trigger was a chargeable event (section 1026) or the employee's death (section 1027)
• Special rules apply where the original relief arose because a non-employee recipient died, or because of a company takeover involving share options — the chapter treats these situations as if the recipient were still alive or the shares were acquired under the original option
• If the qualifying business is transferred within a group, the relief can pass to the successor company under section 1029