BIM44610 - Specific deductions: Employee benefit trusts: general purpose EBT contributions: timing of deductions: FA03/SCH24: computing adjustments: example

This example shows how to compute the amount of deductions for employee benefit contributions which are:

  • Disallowed in computing the employer’s taxable profits for a period to the extent that qualifying benefits or qualifying expenses are not paid within nine months of the end of the period (FA03/SCH24/PARA1 (3)), and
  • Allowed as a deduction in computing the employer’s taxable profits for later periods in which qualifying benefits are paid (PARA1 (4)).

Example

Accounting period ended 31/12/2004

  • Employer has a past pattern of paying bonuses under a discretionary bonus scheme.
  • Employer contributes £1m to EBT to fund likely bonuses for the next 3 years.
  • No qualifying benefits paid 1/1/04 to 30/9/05.
  • No qualifying expenses paid 1/1/04 to 30/9/05.
Deduction in profit and loss account under GAAP
(for constructive obligation to pay bonuses)
£333,333
Disallow under PARA 1(3) (and carry forward)£333,333
Total deduction allowed for tax purposesNil

Accounting period ended 31/12/2005

  • No contribution to EBT.
  • No qualifying benefits paid 1/1/05 to 31/12/05.
Deduction in profit and loss account under GAAP£333,333
Disallow under PARA 1(3) (and carry forward)£333,333
Total deduction allowed for tax purposesNil

Accounting period ended 31/12/2006

  • No contribution to EBT.
  • Qualifying benefits paid to employees = £900,000.
Deduction in profit and loss account under GAAP£233,334
Disallow under PARA 1(3) (and carry forward)Nil
Allow in tax computation under PARA 1(4)£666,666
Total deduction allowed for tax purposes£900,000

Subsequent periods

Maximum deduction still to be allowed under PARA 1(4)Nil
EBT contributions not yet deducted in P&L account£100,000