CG56334 - Employment-related securities: acquired for nothing or at undervalue: employer
If the employing company issues its own new shares, there is no liability in respect of chargeable gains on the employer. An issue of shares by a company is not a disposal of those shares by the company.
If there is a transfer of existing shares or other employment-related securities, there is a disposal by the person transferring them to the employee. The transfer is in connection with the employment so TCGA92/s17 (1)(b) applies and the disposal is at market value. See also CG16270.
The provisions disapplying the market value rule for the acquisition by employees of shares and other employment-related securities
- subject to the risk of forfeiture
- subject to restrictions
- which are convertible
do not apply to employers or others providing them. See CG56321.
The employer바카라 사이트™s disposal proceeds and the employee바카라 사이트™s acquisition costs may, therefore, be different for the same transfer of assets.