Where ITEPA 2003, ss 417–554 (Pt 7) seeks to tax any consideration, or benefit, received in connection with employment-related securities, it would be easy to reduce the taxable value of that consideration or benefit by providing it in the form of further securities, the market value of which has been artificially depressed. This possibility is addressed by ITEPA 2003, s 446I, which provides for an adjustment to the market value of securities (or an interest in securities) used as consideration or benefit.
The market value of securities is considered to have been artificially depressed if it has been reduced by at least 10% as
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