Corporation Tax Act 2009 section 1025B

Application of Chapter where original relief a consequence of section 1007A, 1015A or 1015B

Section 1025B sets out how additional corporation tax relief for chargeable events relating to restricted shares applies where the original relief arose from secondment or cross-border employment arrangements involving overseas companies and UK host companies.

• Where the original share acquisition or option relief was available because of secondment or cross-border employment provisions, the UK host company is treated as the employing company for the purposes of the additional chargeable event relief
• The amount of additional relief available on a chargeable event is capped at the total amount of the employee's employment income that has actually been charged to UK income tax under ITEPA 2003
• Where more than one company could potentially claim relief in respect of the same chargeable event, only one of them may receive the relief
• No relief is available where the chargeable event arises as a result of the employee's death