Related Commentary  Related HMRC Manuals

452(1)  For the relevant tax purposes the market value of the shares (or interest in shares) at the time of the acquisition is to be calculated disregarding the effect on that market value of the intellectual property agreement and any transfer of intellectual property pursuant to it.

452(2)  For the purposes of subsection (1) “the relevant tax purposes” are–

(a)determining any amount that is to constitute earnings from the employment under Chapter 1 of Part 3 (earnings),

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