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The query published in Taxation, 26 April 2001 at page 102 concerned the possibility for a tax deduction for sums recharged to a United Kingdom subsidiary for the 'cost' of stock options granted by a United States parent company to the employees of the subsidiary.
The query published in Taxation 26 April 2001 at page 102 concerned the possibility for a tax deduction for sums recharged to a United Kingdom subsidiary for the 'cost' of stock options granted by a United States parent company to the employees of the subsidiary.
One could get a tax deduction for a payment to a parent company for the provision of employee benefits namely shares in a similar way to getting a tax deduction for a payment to an employee benefit trust. Section 74(1)(a) Taxes Act 1988 should permit this provided it is an income payment. I think the cases on employee trusts e.g. Heather v PE Consulting Group Ltd 48 TC 293 would support this.
The arrangements would represent financial assistance for the purchase of own shares giving concern under section 151 Companies Act. It may well be that...
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