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Much ado about nothing?

15 June 2006 / David Bowes
Issue: 4062 / Categories: Comment & Analysis , Capital Gains , Income Tax
DAVID BOWES considers the present state of play in relation to the valuation of employee shares under ITEPA 2003.

THE SO-CALLED RESTRICTED shares regime was introduced some three years ago when the tax treatment of shares received by employees and chargeable as part of their income was changed. Many problems were envisaged when the new rules were drafted not least those relating to valuation of the shares in question. Shares in unlisted companies are generally by their very nature restricted in some way or other. The questions for practitioners and share valuers included the following:

  • how was the market value requirement of ITEPA dealing with the so-called 'unrestricted' shares to be reconciled with existing law and practice which largely dealt with shares that carried restrictions;
  • were there going to be any changes to the way that valuations were approached in future; and
  • how was the new regime going to work?

Historic position

Prior to ITEPA 2003...

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