Part 7Employment income: share-related income and exemptions
Chapter 4Post-acquisition benefits from shares
Tax charge on increase in value of shares of dependent subsidiaries
456Cases outside charge under section 453
1
Section 453 (charge on increase in value of shares of dependent subsidiary) does not apply in the following cases.
2
Section 453 does not apply if—
a
the chargeable increase arises in relation to a disposal of the employee’s beneficial interest in the shares, and
b
by virtue of section 427 (charge on interest ceasing to be only conditional, etc.), an amount counts as employment income of the employee in respect of the disposal.
3
Section 453 does not apply in relation to shares in a company within subsection (1)(b) of that section (company becoming a dependent subsidiary after acquisition) if the employee has not, at any time in the period of 7 years ending with the date on which the company became a dependent subsidiary, been a director or employee of—
a
the employer company,
b
if different, the company whose shares they are, or
c
an associated company of a company within paragraph (a) or (b).