Revenue Note for Guidance
Where a participant directs the trustees to transfer his/her shares in cash at any time before the release date and the trustees have received a sum equal to tax at the standard rate on an amount representing the appropriate percentage of the locked-in value of the shares, the trustees are charged to tax under Case IV of Schedule D on that amount. The section also gives the participant credit for the tax paid by the trustees.
Relevant Date: Finance Act 2019