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HMRC internal manual

Employment Related Securities Manual

HM Revenue & Customs
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Securities with Artificially Enhanced Value

Effect of artificial increases before acquisition

The following reliefs (see ERSM20290) are not available if the market value of the employment-related securities at the time of their acquisition has been increased by at least 10% by non-commercial increases within the period of 7 years ending with the acquisition, per ITEPA03/S446NA (1) & (2).

  • 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 of charge.

This applies from 7 May 2004.