Corporation Tax Act 2009 section 1030B

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

Section 1030B sets out how additional corporation tax relief for convertible securities applies where the original relief arose because an overseas employee was seconded to, or took up employment with, a UK company.

• Where original employee share relief was available to a UK host company under secondment or similar arrangements involving overseas employees, additional relief for chargeable events on convertible securities may also be available to that host company, which is treated as the employing company for this purpose.
• The chargeable event triggering additional relief may include the conversion of securities into shares in the overseas employer company.
• The amount of additional relief is capped at the total employment income of the employee that has actually been charged to UK income tax — it cannot exceed that amount regardless of what other calculations might suggest.
• Where more than one company could claim relief in respect of the same chargeable event, only one company may receive it, and no relief is available where the trigger is the employee's death.