Corporation Tax Act 2009

1032 Meaning of “chargeable event”

(1) In this Chapter “chargeable event” means an event that—

(a) is a chargeable event for the purposes of section 438 of ITEPA 2003,

(b) is within section 439(3)(a) of ITEPA 2003, and

(c) is within subsection (2).

(2) An event is within this subsection if it is the conversion of convertible securities into shares in relation to which—

(a) if the original relief is or would have been available under Chapter 2, all the conditions set out in section 1008 are met, or

(b) if the original relief is or would have been available under Chapter 3, all the conditions set out in section 1016 are met (ignoring paragraph (f) of condition 3).

(3) Subsection (4) applies if section 438 of ITEPA 2003—

(a) does not apply in relation to the acquired securities, but

(b) would apply if at all material times the employee had been a UK employee.

(4) This Chapter applies as if the employee had been a UK employee as mentioned in subsection (3)(b).

(5) The employee is a UK employee if—

(a) the employee is UK resident and ordinarily UK resident, and

(b) the duties of the relevant employment are performed in the United Kingdom.