E4.507U Employment related securities notional loan provisions—overview
In a situation where shares are acquired for less than market value, and that undervalue is not already subject to tax under the general earnings rules of ITEPA 2003, s 62, the 'notional loan provisions under ITEPA 2003, ss 446Q–446W (Pt 7, Ch 3C) are likely to apply instead.
This article outlines these notional loan provisions, including reference to some exceptions which may apply. For further details on the application of the notional loan tax charge see also E4.507V. For details of the operation of the notional loan charge and further charges which may apply when the 'loan' is deemed to have been repaid or written off, see E4.507W.
The title of ITEPA 2003, ss 446Q–446W (Pt 7, Ch 3C) can be misleading. Where the employee pays
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