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
456Cases outside charge under section 453
(1)
Section 453 (charge on increase in value of shares of dependent subsidiary) does not apply in the following cases.
(2)
Section 453 does not apply if—
(a)
the chargeable increase arises in relation to a disposal of the employee’s beneficial interest in the shares, and
(b)
by virtue of section 427 (charge on interest ceasing to be only conditional, etc.), an amount counts as employment income of the employee in respect of the disposal.
(3)
Section 453 does not apply in relation to shares in a company within subsection (1)(b) of that section (company becoming a dependent subsidiary after acquisition) if the employee has not, at any time in the period of 7 years ending with the date on which the company became a dependent subsidiary, been a director or employee of—
(a)
the employer company,
(b)
if different, the company whose shares they are, or
(c)
an associated company of a company within paragraph (a) or (b).