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HMRC internal manual

Employment Related Securities Manual

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.