331. Priority share allocations.

An employee given priority in a public offer who ends up with more shares than they would have received had they not been an employee would be taxable on the value of the allocated shares in excess of the price paid1. However, an exemption applies where there is a genuine offer to the public and employees at a fixed price or tender provided:

  1.  

    (1)     the number of priority shares is limited and no more than 10 per cent of the shares are offered to the employees in priority;