Part 7Employment income: share-related income and exemptions

Chapter 4Post-acquisition benefits from shares

Tax charge on increase in value of shares of dependent subsidiaries

454Chargeable increases

1

This section applies for the purposes of section 453 (charge on increase in value of shares of dependent subsidiary).

2

In a case within section 453(1)(a) (dependent subsidiary at time of the acquisition) there is a “chargeable increase” in the value of the shares if the value of the shares at the appropriate time exceeds their value at the time of the acquisition.

3

In subsection (2) “the appropriate time” means whichever is the earlier of—

a

the end of the period of 7 years after the date of the acquisition, and

b

the time when the employee ceases to have a beneficial interest in the shares.

4

In a case within section 453(1)(b) (company becoming dependent subsidiary after time of acquisition) there is a “chargeable increase” in the value of the shares if the value of the shares at the appropriate time exceeds their value at the time when the company becomes a dependent subsidiary.

5

In subsection (4) “the appropriate time” means whichever is the earlier or earliest of—

a

the end of the period of 7 years after the date on which the company becomes a dependent subsidiary,

b

the time when the employee ceases to have a beneficial interest in the shares, and

c

if the company ceases to be a dependent subsidiary, the time when it does so.