Corporation Tax Act 2009 section 991

Another deduction to be allowed if all acquired shares are awarded

Section 991 allows a company to reclaim a tax deduction that was previously withdrawn, if all the shares originally acquired are eventually awarded to employees under a share incentive plan.

• This section applies where a deduction for a contribution to a share incentive plan trust was previously withdrawn under section 990.
• If, at any time after the withdrawal, all the acquired shares are awarded to employees under the plan, a new deduction is allowed.
• The deduction is given to the paying company in the period of account in which all acquired shares have been awarded.
• The amount of the deduction equals the original payment made to the plan trust.