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HMRC internal manual

Employment Related Securities Manual

HM Revenue & Customs
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Securities with Artificially Depressed Value

Certain company shares

There are exclusions from the charges in Chapters 2 - 5 for certain company shares (seeERSM20290)

As from 7 May 2004, ITEPA03/S446IA provides that these are not effective if an artificial reduction in value within Chapter 3A has reduced the amount of a charge.

The exclusion covers:

  • ITEPA03/S429 (for restricted securities),
  • ITEPA03/S443 (for convertible securities),
  • ITEPA03/S446R (for a charge under Chapter 3C), and
  • ITEPA03/S449 (for a charge under Chapter 4).

These reliefs would normally take benefits received on certain company shares out ofcharge.