Employment Related Securities Manual

ERSM60020 - Securities with Artificially Enhanced Value

What is artificially enhanced market value?

The provisions in Chapter 3B apply where the market value of employment-related securities (or other relevant securities or interests in securities) is increased by things done otherwise than for genuine commercial purposes.

Otherwise than for genuine commercial purposes

Per ITEPA03/S446A, the following are among the things that are, for the purposes of this Chapter, done otherwise than for genuine commercial purposes 바카라 사이트�

1. Anything done that has as its main purpose (or one of its main purposes) the avoidance of tax or NIC, and
2. Non-arm바카라 사이트檚 length transaction between members of a group of companies other than payments for group relief (ICTA88/S402聽(6)). In this context 바카라 사이트済roup바카라 사이트� means a company and its 51% subsidiaries.

See examples at ERSM60030.

University spin-out companies

There is a specific exemption from the operation of Chapter 3B in Chapter 4A (shares in research institute spin-out companies). Where a company qualifies for relief within that Chapter, under ITEPA03/S455, neither an intellectual property agreement nor any transfer of intellectual property pursuant to such an agreement is regarded as a thing 바카라 사이트渄one otherwise than for genuine commercial purposes바카라 사이트�, see ERSM100010聽et seq.