The purpose of this Practice Note is to explain the circumstances in which a corporation tax (CT) deduction may be available to a company in connection with an employee share scheme arrangement. This Practice Note outlines when a company may be entitled to a CT deduction for costs incurred in setting up and operating an employee share scheme, examines the availability of CT deductions under Part 12 of the Corporation Tax Act 2009 (which allow a CT deduction without the company having to incur a financial outgoing), and looks at corporation tax issues in relation to overseas employees. This Practice Note is written in partnership with Laura Gould of Reed Smith LLP and Justin Rissetto of King & Wood Mallesons.
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