The YA 2026 extension
From YA 2026, qualifying payments to a holding company or scheme SPV for newly issued holding-company shares can be deductible. The deduction is limited to the lower of the company’s payment and the shares’ open-market price at issue or transfer, using net asset value where the price cannot be determined. Employee payments reduce the deduction. A company issuing its own new shares still receives no deduction under this treatment. The guide also simplifies the treasury-share cost rules from YA 2026.
Timing and administration
Options generally use exercise timing, while share awards use vesting or unconditional grant. For a holding-company or SPV recharge, the deduction arises at the later of employee vesting and the company becoming liable for the recharge. The scheme SPV and trust must meet the stated requirements. Retain the share source, acquisition cost, employee contributions, recharge obligation and vesting evidence. Distinguish the employer’s deduction from the employee’s employment-income assessment, and check later IRAS webpage updates when considering historical YA concessions beyond this PDF’s stated regime.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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