Commentary on Sections Overview Chapter 2: SAYE option schemes, Company share option schemes and Employee share options trusts Section 1000: Deduction for costs of setting up employee share ownership trust
2578.This section gives relief for the costs of setting up a qualifying employee share ownership trust (QUEST). It is based on sections 21A, 75 and 85A of ICTA.
2579.In practice it is unlikely that a QUEST would be set up in an accounting period to which this Act applies. Section 67 of FA 1989 gave relief for employers’ contributions to QUESTs. That relief was withdrawn by section 142 of FA 2003 with effect for contributions made in accounting periods beginning on or after 1 January 2003. Relief for the provision of shares through a QUEST is given now by Schedule 23 to FA 2003, rewritten in Part 12 of this Act.
2580.The relief given by section 85A of ICTA for the setting up costs was not withdrawn and is still available in the event that a company did set up a new QUEST. The section is very similar to section 999.
2581.This Act does not rewrite section 85 of ICTA (payments to trustees of approved profit sharing schemes). Approved profit sharing schemes were phased out by section 49 of FA 2000, and the deduction in section 85 of ICTA was phased out by section 50 of FA 2000. This Act accordingly does not rewrite section 85 of ICTA (or section 50 of FA 2000).