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Home / Simons-Taxes /Personal and employment tax /Part E4 Employment income /Division E4.5 Income and exemptions relating to securities /Employment related securities with artificially enhanced market value / E4.507R Securities with artificially enhanced market value—overview
Commentary

E4.507R Securities with artificially enhanced market value—overview

Personal and employment tax

E4.507R Securities with artificially enhanced market value—overview

ITEPA 2003, ss 446K–446P (Pt 7, Ch 3B) aims to charge to income tax artificial increases in the value of employment-related securities. It operates, broadly speaking, on events within each tax year.

This article outlines how this anti-avoidance charge works, and provides some numeric examples. For further information on:

  1. Ìý

    •ÌýÌýÌýÌý how the tax charge on securities with artificially enhanced market value operates, see E4.507S

  2. Ìý

    •ÌýÌýÌýÌý restricted securities with artificially enhanced market value, see E4.507T

  3. Ìý

    •ÌýÌýÌýÌý disapplication of exceptions, which may apply to securities with artificially enhanced market value, see E4.507TA

Application

For ITEPA 2003, ss 446K–446P (Pt 7, Ch 3B) to apply, the market value of employment-related securities must have been increased by 'things done otherwise than for genuine commercial purposes'1. It has already been remarked (see E4.507M)

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