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Deferred Shares

Rule	Response
Time of taxable event	An income tax liability arises at the date of vest, i.e. at the end of the restriction period.
Taxable amount	The taxable amount will be the market value of the share at the date of vest.
Definition of market value	HMRC accepts that the closing mid-market price (i.e. half way between the closing bid and offer prices for that day) is a reliable indicator of the market value for shares traded on a foreign exchange.

Rights (deferred share rights or performance rights)

Rule	Response
Time of taxable event	An income tax liability arises at the date of exercise.
Taxable amount	The taxable amount will be the market value of the underlying shares at exercise.
Definition of market value	HMRC accept that the closing mid-market price (i.e. half way between the closing bid and offer prices for that day) is a reliable indicator of the market value for shares traded on a foreign exchange.

ESO Incentive

Rule	Response
Time of taxable event	An income tax liability arises at the date of vest, i.e. at the end of the restriction period.
Taxable amount	The taxable amount will be the market value of the share at the date of vest.
Definition of market value	HMRC accepts that the closing mid-market price (i.e. half way between the closing bid and offer prices for that day) is a reliable indicator of the market value for shares traded on a foreign exchange.

Deferred Shares

Rule	Response
Time of taxable event	An income tax liability arises at the date of vest, i.e. at the end of the restriction period.
Taxable amount	The taxable amount will be the market value of the share at the date of vest.
Definition of market value	HMRC accepts that the closing mid-market price (i.e. half way between the closing bid and offer prices for that day) is a reliable indicator of the market value for shares traded on a foreign exchange.

Rights (deferred share rights or performance rights)

Rule	Response
Time of taxable event	An income tax liability arises at the date of exercise.
Taxable amount	The taxable amount will be the market value of the underlying shares at exercise.
Definition of market value	HMRC accept that the closing mid-market price (i.e. half way between the closing bid and offer prices for that day) is a reliable indicator of the market value for shares traded on a foreign exchange.

ESO Incentive

Rule	Response
Time of taxable event	An income tax liability arises at the date of vest, i.e. at the end of the restriction period.
Taxable amount	The taxable amount will be the market value of the share at the date of vest.
Definition of market value	HMRC accepts that the closing mid-market price (i.e. half way between the closing bid and offer prices for that day) is a reliable indicator of the market value for shares traded on a foreign exchange.