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05 November 2013
Restricted securities taxation as explained to students of Tolley Exam Training
KEY POINTS
- Acquisition of shares gives rise to a charge under s 62.
- Charge is on restricted value where there is a disposal restriction or more than a five-year forfeiture period.
- Further charge on lifting of restriction based on percentage of unrestricted value not yet charged or paid for.
- Elections to disapply may be beneficial if value expected to rise.
Since we have all at some point referred back to our student manuals to refresh our memories on topics we have not recently encountered we thought it would be useful for students and practitioners alike to read this edited extract from Tolley Exam Training’s Personal Income Tax Study Manual on the taxation of employment related securities subject to a restriction. All references are to ITEPA 2003 unless stated otherwise.
First...
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