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Commentary

E4.507S Operation of the charge on securities with artificially enhanced market value

Personal and employment tax

Charges under ITEPA 2003, ss 446K–446P (Pt 7, Ch 3B) are made in relation to the value of employment-related securities at a 'valuation date' (see below) for a 'relevant period'1.

A 'relevant period' begins with the acquisition of the employment-related securities and ends at the following 5 April2 (although securities acquired before 16 April 2003 are for these purposes deemed to have been acquired on that date3). Rights under contracts of insurance acquired before 2 December 2004 (when such rights were brought within the definition of securities, subject to specified exclusions, see E4.507A) are deemed to have been acquired at 2 December 2004 for this purpose4.Thereafter each tax year forms a relevant period5. A relevant period may end other than on 5 April if ITEPA 2003, ss 446K–446P (Pt 7, Ch 3B) ceases to apply to the employment-related securities6.

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