ETASSUM23120 - Schedule 2 share incentive plan (SIP): Shares that may be awarded: When requirements must be satisfied

Eligible shares must meet the relevant requirements of Schedule 2:

• at the time when shares are acquired by the trustees of the plan for the purpose of making awards to participants, and
• at the date when the shares are awarded to participants under the rules of the Schedule 2 SIP.

It is important that:

• the shares satisfy the relevant requirements when the plan trustees acquire them because the CT deduction may depend on it,

• the shares satisfy the relevant requirements at the date of award because a Schedule 2 SIP must provide for participants to acquire:

• shares that satisfy paragraph 26-29, or
• shares that replace such shares following a capital re-organisation and are equivalent for CGT purposes.