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HMRC internal manual

Employment Related Securities Manual

Securities Options: employee deprived of securities by operation of law

Where the employee is deprived of the option by operation of law, per ITEPA03/S476(5), the “relevant person” is chargeable to tax under ITTOIA05/S687 (charge to tax on income not otherwise charged - old Case VI of Schedule D) using the calculation basis set out in ITEPA03/S478.

In this context, “relevant person” means the person who acquired the securities or the consideration or benefit.