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HMRC internal manual

Employment Related Securities Manual

Employment-related securities and options: Ede v Wilson (26TC381)

A similar point arose in Ede v Wilson (26TC381). In that case, a group of employees were allotted shares on the condition that, as long as they continued to work for the company, they could not sell them without the permission of the company’s directors. The Court held that the shares were still emoluments, or earnings, even though there was a restriction on sale. The restriction was simply a factor to be taken into account in determining the value of the earnings.