Section 326 | Expenses incidental to transfer of a kind not normally met by transferor

(1)No liability to income tax arises by virtue of the payment or reimbursement of expenses which—

(a)are incidental to, and incurred wholly and exclusively as a result of, an employment-related asset transfer, and

(b)are of a kind not normally met by the transferor.

(2)There is an “employment-related asset transfer” if—

(a)an asset or the beneficial interest in an asset is transferred to an employee’s employer or a person nominated by the employer, and

(b)the right or opportunity to make the transfer arose by reason of the employment.

(3)In this section references to a transfer are to a sale or any other kind of disposal.