Related Commentary  Related HMRC Manuals

446T(1)  The amount of the notional loan initially outstanding is–

MV − DA

where–

MV is the market value of the employment-related securities at the time of the acquisition, and

DA is the total of any deductible amounts.

446T(2)  Where the employment-related securities are, or are an interest in, securities which are not fully paid up, the reference in subsection (1) to the market value of the employment-related securities is to what it would be if the securities were fully paid up.

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