Securities with Artificially Depressed Value
Restricted Securities from 16 April 2003 to 6 May 2004
A change was brought in from 7 May 2004 so that, where securities were disposed of in such a way that there was not a chargeable event under s.427 (3) (eg disposal for nil consideration), there was a deemed chargeable event immediately before the securities were disposed of. This affected the occasions on which a charge was triggered and also when the ‘relevant date’ might be.
Before 7 May 2004 the modification of the Chapter 2 charge applied as follows:
ITEPA03/S446E applies where the market value of employment-related restricted securities is artificially low on the earliest of the following dates:
- immediately after an event which is a chargeable event (see ERSM30390) in relation to the securities for the purposes of ITEPA03/S426 (charge on restricted securities), or
- on 5th April in any year.
The “relevant date” is –
- the date on which the chargeable event concerned occurs, or
- if neither, then the relevant 5th April.
See ERSM50100 for use of acquisition charge under ITEPA03/S446B & ITEPA03/S446C in certain circumstances.