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.