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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

Schedule 2 share incentive plan (SIP): Shares that may be awarded: Recognised stock exchange (RSE)

Further to the guidance at ETASSUM23220 onwards a “Recognised Stock Exchange” (RSE) is defined in Section 1005(1) ITA 2007 as:

  • any market of a recognised investment exchange designated as a recognised stock exchange by an order made by the Commissioner for HMRC, and
  • any market outside the UK designated in such an order.

There is a list of such exchanges on GOV.UK (Table 1) and also a list of countries (Table 2) where any stock exchange which is within the relevant jurisdiction’s law relating to stock exchanges will have RSE status.

The phrase ‘listed on a recognised stock exchange’ in respect of shares and securities is defined at section 1005(3) ITA 2007. It means shares and securities which are:

  1. admitted to trading on that exchange, and
  2. included in the official UK list maintained by the Financial Services Authority (in its capacity as the UK Listing Authority) or are officially listed in a qualifying country outside the UK in accordance with provisions corresponding to those generally applicable in EEA states.

Shares on the AIM (the Alternative Investment Market which came into being in July 1995) or Plus Market do not satisfy the requirements of paragraph 27(1)(a). Although these markets are part of the Stock Exchange, shares are not “listed” on them, i.e. included on the Official List.