Commentary on Sections Overview Overview
1427.This Chapter is based on sections 686B and 686C of ICTA.
1428.Under a share incentive plan, shares which are not “plan shares” (see paragraph 99(1) of Schedule 2 to ITEPA) are held on accumulation or discretionary trusts. So the trustees’ dividend income arising from such shares is potentially chargeable at the dividend trust rate under section 479. But this Chapter provides that such a charge on approved plans does not arise if the shares are awarded to participants in the plan within an “applicable period” (defined in section 489).