A special rule applies in relation to restricted employment-related securities to ensure that ITEPA 2003, ss 422–432 (Pt 7, Ch 2) interacts correctly with the other chapters in ITEPA 2003, ss 417–554 (Pt 7). The intention is simply that, if the tax-advantaged scheme is intended to provide the shares free of income tax on acquisition, then it is reasonable to assess that exemption etc based on the shares' full unrestricted value1.
Accordingly, it is provided that where restricted shares are acquired
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