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HMRC internal manual

Employment Related Securities Manual

From
HM Revenue & Customs
Updated
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Restricted securities: securities disposed of for less than market value

The computation in ITEPA03/S428 (1) is based on the unrestricted market value at the time of a chargeable event. Where there is a disposal of restricted securities and the employee receives less than the actual market value the answer given by the formula in ITEPA03/S428 (1) is modified by ITEPA03/S428 (9) by multiplying it by the following formula:

CD/AMV

where:

  • CD is the consideration given for the employment-related securities, and
  • AMV is the actual market value of the employment-related securities immediately after the chargeable event.

No relief if avoidance

The above adjustment is not available if something which affects the employment-related securities has been done (at or before the time of the chargeable event) as part of a scheme or arrangement the main purpose (or one of the main purposes) of which is the avoidance of tax or national insurance contributions.