Revenue Note for Guidance
This section removes a double charge to USC on both the initial market value of shares when they are appropriated to an approved profit sharing scheme trust and, later in the event of an early disposal, on the proceeds where those shares are sold under section 512, or where income, known as a capital receipt, is received under section 513.
Where USC has been charged on the initial market value of shares when they are appropriated to an approved profit sharing scheme trust it is not subsequently charged on the locked-in value of those shares (within the meaning of section 512(1)) in the event of an early disposal of the shares or on the amount or value of a capital receipt (within the meaning of section 513(1)) where a capital receipt is subsequently received before the end of the required holding period for the shares.
Relevant Date: Finance Act 2019