BIM44130 - Measuring the profits (specific rules & practices) - receipts & deductions: specific deductions - employee share schemes: providing shares - accounting periods starting before 1 January 2003: contributions to qualifying employee share ownership trusts (QUESTs) - relief not claimed under FA89/S67
Payments to qualifying employee share ownership trusts which are not claimed as deductible under FA89/S67 will only be allowable deductions under general Schedule D principles, or as expenses of management, if they are:
- not capital in nature and satisfy the wholly and exclusively test of ICTA88/S74 (1)(a),
- are properly regarded as an expense of management within ICTA88/S75.
Guidance on deductions for contributions to employee share ownership trusts under general Schedule D (‘case law’) principles is at BIM44140 onwards.