Income Tax (Earnings and Pensions) Act 2003 section 547

Meaning and amount or value of "registrant discount"

Section 547 defines what a "registrant discount" is in the context of company share offers that include both the public and employees, and explains how its amount or value is determined.

  • A "registrant discount" exists when members of the public who register or meet offer requirements become entitled to a discount on shares allocated to them, and at least 40% of shares allocated to the public go to individuals entitled to that discount (or an equivalent alternative benefit).
  • Directors and employees who receive a priority share allocation by virtue of their office or employment are excluded from being counted as "members of the public" when applying the 40% test.
  • Subscribing employees — directors or employees who apply for shares through the public offer (or, where separate offers exist, through either offer) and comply with the same registration requirements as the public — must be entitled to the same discount as other public applicants.
  • The "amount or value" of the registrant discount for a director or employee is either the monetary amount of the discount itself or, where an alternative benefit of similar value is chosen instead, the value of that benefit.

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