Notional loan

ITEPA03/S446T determines the amount of the notional loan initially outstanding. This is defined in subsection (1) as:

MV – DA

where

MV is the market value (as if the securities were fully paid up and disregarding any outstanding debt due) of the employment-related securities at the time of acquisition (or deemed acquisition, per ITEPA03/S446Q (4)), and

DA is the total of deductible amounts.

Definition of market value

Market value follows the TCGA92/S272 definition (see ERSM20400).

Deductible amounts

Deductible amounts comprise, per subsection (3) of ITEPA03/S446T:

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