ETASSUM23200 - Schedule 2 share incentive plan (SIP): Shares that may be awarded: Swiss bearer participation certificates
Swiss Bearer Participation Certificates (SBPCs) with par value, as distinct from Profit Sharing Certificates will qualify as ordinary share capital for the purposes of paragraph 26 provided the requirements of Part 4 of Schedule 2 ITEPA are met.
See https://www.gov.uk/guidance/employment-related-securities-bulletin-31-march-2019#definition-of-ordinary-share-capital-for-employee-share-schemes and /manual/company-taxation-manual/ctm00512