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HMRC internal manual

Employment Related Securities Manual

Restricted Securities: Shares acquired before 16 April 2003: year and amount of charge

A post-acquisition charge may be made on more than one occasion if there is a succession of chargeable events. If an employee’s interest in the shares is less than full beneficial ownership the charge is made on an ‘appropriate part’ of the amount by which the shares have increased in value.

It is conceivable that some other event, such as a sudden sharp movement in Stock Exchange prices, might have the effect of disguising a chargeable event. In such circumstances the legislation would still permit an Income Tax charge to be made.