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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

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.