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KEN MOODY considers the corporation tax relief for employment related securities under FA 2003, Sch 23
KEY POINTS
- The basis of the corporation tax deduction for employment related securities
- The particular rules for different types of shares
- The effect of an ITEPA 2003 s 431 election
- HMRC's interpretation of the EMI rules
- The calculations for EMI options
I have recently exchanged several e-mails with a former colleague about the corporation tax deduction under FA 2003 Sch 23 in respect of employment related securities (ERS).
These concerned some of the 'fine print' of the legislation where enterprise management incentive (EMI) options are involved and I must say the proverbial 'wet towel' could have been handy.
Broadly the corporation tax deduction is based upon the amount chargeable on the employee and is a very useful relief in making share incentive arrangements tax effective.
However quantifying the amount...
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