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HMRC internal manual

Employment Income Manual

PAYE: meaning of readily convertible assets: asset capable of being sold on a specified market

Section 702(1)(a)(iv) ITEPA 2003

This legislation provides the power for the Commissioners of HMRC to specify a market in the event that HMRC becomes aware of a PAYE avoidance arrangement being used that relies on the provision of an asset that can be sold or otherwise realised on a market other than a recognised investment exchange, the London Bullion Market or the New York Stock Exchange.

Trading arrangements

In general, any other market or exchange provides for shares to be sold on any trading day and this facility satisfies the alternative definition of readily convertible asset based on the existence of trading arrangements (see EIM11910). Accordingly shares listed on an alternative market will be readily convertible assets.