Taxes Consolidation Act 1997 section 531AUA

Universal social charge and approved profit sharing schemes

Section 531AUA prevents a double charge to universal social charge (USC) on shares received under an approved profit sharing scheme (APSS) where USC has already been charged on the initial market value of the shares at the time of appropriation.

• Where USC has been charged on the initial market value of shares appropriated to an APSS trust, it is not charged again on a subsequent disposal or deemed disposal of those shares.
• The exemption from the second charge applies to the appropriate percentage of the locked-in value of the shares, as defined in section 512(1).
• Where a capital receipt (within the meaning of section 513(1)) arises in respect of the shares, USC is not charged on the appropriate percentage of the amount or value of that capital receipt.
• The relief ensures that shares which have already borne USC on their initial market value are not subject to a further USC charge when they are disposed of early or give rise to income during the required holding period.