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HMRC internal manual

Employment Related Securities Manual

HM Revenue & Customs
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Restricted securities: securities acquired for purposes of avoidance - deemed election under Section 431(1)

Where employment-related securities are restricted securities or a restricted interest in securities, the employer and the employee are to be treated, per ITEPA03/S431B, as making an election under ITEPA03/S431 (1) in relation to the employment-related securities if the main purpose (or one of the main purposes) of the arrangements under which the right or opportunity to acquire the employment-related securities is made available is the avoidance of income tax or National Insurance contributions.