Further provisions are relevant where the employment-related securities that have artificially increased in value are restricted securities at the valuation date, or where they have been restricted securities at some point in the relevant period (whether or not they are still restricted securities at the valuation date)1.
Restricted securities—modification of charge
Where employment-related securities are still potentially within the ITEPA 2003, ss 422–432 (Pt 7, Ch 2) charge on restricted securities at some point in the future then, to avoid a double charge, relief is provided for any artificial increases still to be charged through ITEPA 2003, ss 422–432 (Pt 7, Ch 2). As a result an adjustment to the formula for the taxable amount (IMV − MV) is needed where restrictions are in place at the valuation date2.
The formula is thus modified to (IMV − MV) × CP, where CP is the chargeable proportion. CP is defined as 1 − OP, where OP is the outstanding proportion. OP is determined as it would be for a chargeable
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