ERSM30060 - Restricted Securities
Taxation treatment: shares acquired between 26 October 1987 and
15 April 2003: exemption from charge
There are circumstances in which an event in one of the
categories set out in
ERSM30080 will have increased the value
of shares acquired by an employee within ITEPA03/S451 (as
originally enacted), but a charge to tax on employment income will
not arise. The exceptions from the charge are designed to apply
where either the:
- shareholder's relationship with the
company is no longer that of an employee or director, the 7 year
rule (see
ERSM30070), or
- increase in value has benefited all
shareholders in the class equally and because of the pattern of
shareholdings in the company, can be accepted not to have been
organised with a view to rewarding employees (see ERSM30080); and
the conditions in
ERSM30090 have been satisfied.
