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In most cases, the occasions of charge in ITEPA 2003, ss 422–450 (Pt 7, Chs 2–4) will fall within the ambit of PAYE. As explained below, the application of PAYE is largely, but not entirely, dependent on the employment-related securities in question being readily convertible assets. In this connection, the amendment to the meaning of 'readily convertible asset' in ITEPA 2003, s 702 is highly significant (see E4.1124). Broadly, following this amendment, securities that are not readily convertible assets will be treated as if they were, unless the securities are shares that are corporation tax deductible¹. HMRC have provided a helpful flowchart which summarises when PAYE applies².

PAYE applies on designated occasions of charge in ITEPA 2003, ss 422–450 (Pt 7, Chs 2–4) where an amount falls to be treated as employment income which is deemed to have been received on the 'relevant date'. Those occasions of charge and the relevant date for each are³ as follows:

1. Ìý

   (a)ÌýÌýÌýÌý Chargeable events relating to restricted securities (and interests in securities)⁴ (see E4.507C).