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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

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HM Revenue & Customs
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Schedule 4 Company Share Option Plan (CSOP): Requirements relating to options: Unlisted shares and shares not listed on any RSE

Where the scheme shares are:

  • unlisted shares, or
  • listed on AIM,

the general definition of market value in Section 272(1) TCGA 1992 applies. Such schemes should require market value to be agreed with HMRC Shares & Assets Valuation (SAV) for the purposes of the scheme, see ETASSUM44180.

Although SAV may, in practice, accept AIM dealings, as reliable indicators of their market value, the scheme rules of such companies should still require market value to be agreed with SAV (see ETASSUM44150).