There is an income tax charge on acquisition where the market value of employment-related securities, as measured at the time of acquisition, has been reduced by at least 10% as a result of non-commercial activity in the preceding seven years1. A 'taxable amount' (see below) is included in the employee's employment income for the tax year in which the acquisition falls2.
These provisions would seem to present significant difficulties in the matter of valuation and in attributing causation. It may be that their main function is one of deterrence, so that they remain relatively unused. Alternatively, it may be that the operation of
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