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HMRC internal manual

Employment Related Securities Manual

HM Revenue & Customs
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Where to find the legislation

Since 1966, there have been a number of provisions to deal with employment-related securities, many of which were introduced to combat avoidance of income tax and NICs. The main provisions were in Finance Acts 1988 and 1998, subsequently consolidated into ICTA1988. In 2003, the Tax Law Rewrite programme rewrote these provisions as the Income Tax Earnings & Pensions Act 2003 (ITEPA). Shortly after this, the tax regime was significantly reformed in Schedule 22 of Finance Act 2003, to provide a fairer, more coherent and consistent regime and deal with further extensive avoidance. As a result, ITEPA was extensively amended to include the FA 2003 changes. Since then ITEPA has been amended in relation to employment-related securities by various subsequent Finance Acts.