Income Tax (Earnings and Pensions) Act 2003 section 461

Related acquisitions of additional shares

Section 461 deals with the tax treatment of additional shares received by an employee in connection with an original shareholding that was acquired by virtue of their employment.

• When an employee receives additional shares related to an original employment-linked shareholding, those new shares are brought within the scope of the restricted shares rules.
• The additional shares are treated as having been acquired at the same time as the original shares for the purposes of these provisions.
• An award of additional shares may itself give rise to a taxable benefit under the rules for notional loans in connection with employment-related shares.
• The deemed acquisition date for the additional shares does not override the actual date on which any separate tax charge arises on the receipt of those shares.