Part 7Employment income: income and exemptions relating to securities

F1Chapter 3Convertible securities

Tax charge on post-acquisition chargeable events

439Chargeable events

(1)

This section applies for the purposes of section 438 (charge on occurrence of chargeable event).

(2)

Any of the events mentioned in subsection (3) is a “chargeable event” in relation to the employment-related securities.

(3)

The events are—

(a)

the conversion of the employment-related securities (or the securities in which they are an interest) into securities of a different description in circumstances in which an associated person is beneficially entitled to the securities into which the employment-related securities are converted,

(b)

the disposal for consideration of the employment-related securities, or any interest in them, by an associated person otherwise than to another associated person (at a time when they are still convertible securities or an interest in convertible securities),

(c)

the release for consideration of the entitlement to convert the employment-related securities (or the securities in which they are an interest) into securities of a different description, and

(d)

the receipt by an associated person of a benefit in money or money’s worth in connection with the entitlement to convert (other than securities acquired on the conversion of the employment-related securities or consideration such as is mentioned in paragraph (b) or (c)).

(4)

A benefit received on account of any disability (within the meaning of F2the Equality Act 2010 in England and Wales and Scotland, or the Disability Discrimination Act 1995) of the employee is to be disregarded for the purposes of subsection (3)(d).