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HMRC internal manual

Employment Related Securities Manual

University Spin-outs

Other reliefs available

The relief available in Chapter 4A may not be required in some circumstances.

  1. Relief is provided already in Chapter 2 (ITEPA03/S429), Chapter 3 (ITEPA03/S443), Chapter 3C (ITEPA03/S446R) and Chapter 4 (ITEPA03/S449) for certain company shares (see ERSM20290). An individual shareholder or group of shareholders may qualify for relief under these provisions even if it is not specifically mentioned in the examples that follow.
  2. Many companies are “spun out” from research institutions but are predominantly service companies. If such a spin-out does not involved the transfer of Intellectual Property from the institution to shares owned or acquired by employees then there is unlikely to be a taxable event within Part 7 of ITEPA in the first place.