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HMRC internal manual

Employment Related Securities Manual

Securities with Artificially Depressed Value

Adjustment of consideration or benefit received

ITEPA03/S446I applies where any consideration or benefit mentioned in—

* ITEPA03/S428 (9) (consideration on disposal of restricted securities) ERSM30410
* ITEPA03/S441 (4), (5) or (9) (consideration for disposal of convertible securities or release of entitlement to convert or benefit received in respect of entitlement to convert) ERSM40080
* ITEPA03/S446C (4) (securities with artificially depressed market value: MV to be amount of consideration) ERSM50100
* ITEPA03/S446X and ITEPA03/S446Y (3) (consideration for disposal of securities exceeding market value), or ERSM80030
* ITEPA03/S448 (securities benefit not otherwise subject to tax) ERSM90020

consists (in whole or in part) in the provision of securities the market value of which is artificially low.

The market value of any securities is artificially low where it has been reduced by atleast 10% as a result of things done otherwise than for genuine commercial purposes within the period of 7 years ending with the receipt of the consideration or benefit.


The market value of the consideration or benefit is increased by the amount of the depreciatory transaction.