Income Tax (Earnings and Pensions) Act 2003 section 439

Chargeable events

Section 439 defines the specific events that trigger an income tax charge under section 438 when an employee holds convertible securities — that is, securities that can be changed into a different type of security.

• A chargeable event arises when convertible employment-related securities are actually converted into securities of a different description, provided an associated person is beneficially entitled to the resulting securities.
• A chargeable event also arises when an associated person sells the convertible securities (or an interest in them) for consideration to someone who is not an associated person.
• Releasing or giving up the right to convert the securities in exchange for consideration, or receiving any benefit in money or money's worth connected with the conversion entitlement, are also chargeable events.
• Any benefit received on account of a disability of the employee (as defined by the Equality Act 2010 or the Disability Discrimination Act 1995) is excluded and does not trigger a charge.