| Commentary

52.4.1 Basic approach

| Commentary

52.4.1 Basic approach

The memorandum of understanding between the British Venture Capital Association and HM Revenue and Customs sets out the approach that HMRC accepts in determining whether the price paid for the relevant managers’ shares is initial unrestricted market value (‘IUMV’)1 where the managers’ shares are ‘restricted’ securities2, or market value where they are not3. The approach set out in the Memorandum provides a ‘safe harbour’ and so does not affect the right of any taxpayer to argue that a different interpretation should apply to his specific circumstances4. HMRC however will not

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