Part 2 “Good Leavers” (Other than Retirees)

Part 2 “Good Leavers” (Other than Retirees)

Introduction

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Part 7 of ITEPA 2003 (employment income: income and exemptions relating to securities) is amended as follows.

Share incentive plans

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In section 498 (no charge on shares ceasing to be subject to plan in certain circumstances) after subsection (2) insert—

“(3)     A participant is not liable to income tax on shares (“the relevant shares”) in a company (“the relevant company”) being withdrawn from the plan if—

(a)     the withdrawal of the relevant shares from the plan relates to—

(i)     a transaction resulting from a compromise, arrangement or scheme falling within subsection (9),

(ii)     an offer forming part of a general offer falling within subsection (10), or

(iii)     the application of sections 979 to 982 or 983 to 985 of the Companies Act 2006 in the case of a takeover offer (as defined in section 974 of that Act) falling within subsection (13), and

(b)     as a result of, as the case may be—

(i)     the transaction,

(ii)     the offer, or

(iii)     the application of sections 979 to 982 or 983 to 985 of the Companies Act 2006,

the participant receives cash (and no other assets)

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