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HMRC internal manual

Employment Related Securities Manual

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.

Relevant date

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.