Income Tax (Earnings and Pensions) Act 2003 Schedule 3 paragraph 20

Shares must be fully paid up and not redeemable

Section 20 sets out two fundamental requirements that shares must meet in order to qualify as eligible shares under a Save As You Earn (SAYE) option scheme.

• Shares used in an SAYE option scheme must be fully paid up at the point of acquisition
• Shares must not be redeemable, meaning the company cannot buy them back on predetermined terms
• Both conditions must be satisfied for shares to qualify as eligible shares under the scheme
• These requirements help ensure that participants receive shares of genuine and lasting value