Tax treatment

FORTHCOMING CHANGE: On 28 October 2026, as part of Budget 2026, it was announced that the lifetime limit for business asset disposal relief will be reduced from £1 million to £500,000 with effect from 6 April 2027. Transitional rules will apply in respect of contracts entered into but not completed, and for certain share reorganisations and exchanges of securities not completed, before 6 April 2027. This document is being updated to reflect these changes. See: Budget paras 2.53 and 6.261 and OOTLAR para 1.33.

Employment-related securities

A security (which includes shares, debt, derivatives and interests in investment partnerships) will be an employment-related security where the right or opportunity to acquire the securities (or interest in securities) is:

  1. •

    available by reason of an employment of the person acquiring the securities (or interest) or any other person, or

  2. •

    made available by a person's employer (or a person connected with a person's employer) (the deeming provision) unless such right or opportunity is made available:

    1. ◦

      by an individual, and

    2. ◦

      in the normal course of the domestic, family or personal relationships of that individual

The rules on employment-related...

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