325. Shares in research institution spin-out companies.

If the taxpayer receives shares in research institution spin-out companies and there is a transfer of intellectual property ('IP') to or from one or more research institutions to the spin-out company a tax charge does not arise in respect of the benefits of the IP transfer1. The person acquiring the shares must be a researcher, the shares in the spin-out company must be acquired before the IP transfer agreement or within 183 days afterwards, and the opportunity to acquire the shares must arise by reason of the employment by the research institutions or company