3.3.1 Before FA 2003

Before FA 2003 there had been two disjointed tax regimes in place that dealt with the situation where shares granted to employees were subject to a risk of forfeiture (the ‘conditional shares’ regime) or subject to restrictions on their rights.

Although both regimes remain technically in force, they only apply to shares that were acquired by reason of employment before 16 April 2003 and, in consequence, are increasingly rarely encountered in practice.

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