HMRC have published new guidance in their Business Income Manual at BIM44410–BIM44414 on the availability of corporation tax relief for cash cancelled or net-settled employee share options. Whilst this is welcome in confirming that ‘general principles’ corporation tax relief is potentially available where specific statutory relief is not, in some scenarios HMRC’s view on the timing of corporation tax relief may cause practical difficulties for some companies. Further, an understanding of whether an award is an ‘option’ is fundamental to applying the corporation tax rules correctly.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
HMRC have published new guidance in their Business Income Manual at BIM44410–BIM44414 on the availability of corporation tax relief for cash cancelled or net-settled employee share options. Whilst this is welcome in confirming that ‘general principles’ corporation tax relief is potentially available where specific statutory relief is not, in some scenarios HMRC’s view on the timing of corporation tax relief may cause practical difficulties for some companies. Further, an understanding of whether an award is an ‘option’ is fundamental to applying the corporation tax rules correctly.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
