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HMRC internal manual

Employment Related Securities Manual

Employer Interface

Timing of relief: Intermediaries: FA03/Sch24

FA03/SCH24 applies to deductions which would otherwise be allowed in computing an employer’s taxable profits for a period ending on or after 27 November 2002, in respect of ‘employee benefit contributions’ made by employers on or after 27 November 2002.

Although FA03/Sch24 is sometimes described as applying to Employee Benefit Trusts, the term ’Employee benefit contributions’ has a broad definition. FA03/Sch24 applies to payments by an employer to a third party who is required or entitled to use them to provide benefits to employees under a trust, scheme or other arrangement. It applies to intermediaries who may be required, or may have discretion, to use them to provide benefits to employees of the employer.

FA03/Sch24 does not apply to:

  • Qualifying share ownership trusts falling under FA89/S67.
  • Approved share ownership plans falling within ICTA88/Sch4AA
  • Share schemes falling within FA03/Sch23

Guidance on relief under FA03/Sch24 can be found at BIM44575 onwards.