Income Tax (Earnings and Pensions) Act 2003 section 451

Application of this Chapter

Section 451 sets out the conditions that must be met for the special tax treatment under Chapter 4A to apply to shares acquired by researchers in spin-out companies formed to commercialise intellectual property from research institutions.

• There must be an agreement to transfer intellectual property from one or more research institutions to a spin-out company
• A person must acquire shares in the spin-out company either before the intellectual property agreement is made or within 183 days after it is made
• The opportunity to acquire the shares must arise because of the person's employment with the research institution or the spin-out company
• The person must be involved in research relating to the intellectual property being transferred under the agreement