The charge to tax on employment income is made for the year of
assessment in which the chargeable event occurs. The amount to be
charged is the amount by which the value of the shares has been
increased by the chargeable event, per FA88/S78(3), which became
ITEPA03/S451 (as originally enacted).
A post-acquisition charge may be made on more than one
occasion if there is a succession of chargeable events. If an
employee's interest in the shares is less than full beneficial
ownership the charge is made on an 'appropriate part' of the amount
by which the shares have increased in value.
It is conceivable that some other event, such as a sudden
sharp movement in Stock Exchange prices, might have the effect of
disguising a chargeable event. In such circumstances the
legislation would still permit an Income Tax charge to be made.
