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HMRC internal manual

Employment Income Manual

The year that earnings are “for” - Long Term Incentive Plans and Deferred Remuneration - staged vesting

Some Long Term Incentive Plans (LTIPs) pay out awards in tranches. The details of different schemes will vary. For example, an LTIP fund containing deferred bonuses and matching awards may pay out 20% per annum over five years or nothing in Years 1 and 2 and 33% per annum in Years 3 to 5. Entitlement may be conditional upon participants meeting performance conditions and remaining in employment.

The period that each tranche is “for” has to be determined. If the evidence shows that the Plan is intended to reward performance over the period from award to vest, each part of the final payment is “for” the period from the original award date until it vests, calculated as per Section 16(4) on a just and reasonable apportionment. In the first example, 20% is “for” Year 1; 20% is “for” Years 1 and 2, and so on. Alternatively, if there are no performance conditions and the Plan emphasises being in employment at each vesting date, each payment may be treated as earnings “for” the tax year of receipt.