{
  "url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003/section-446H",
  "json_url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003/section-446H.json",
  "legislation": "ukpga/2003/1",
  "legislation_title": "Income Tax (Earnings and Pensions) Act 2003",
  "legislation_url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003",
  "path": "section/446H",
  "kind": "section",
  "number": "446H",
  "heading": "Adjustment of market value: charge on conversion",
  "text": "(1) This section applies where the market value of securities (“the converted securities”) into which employment-related securities (or securities in which employment-related securities are an interest) are converted is artificially low at the time of an event which is a chargeable event in relation to the employment-related securities by virtue of section 439(3)(a) (conversion).\n(2) The market value of the converted securities is artificially low where it has been reduced by at least 10% as a result of things done otherwise than for genuine commercial purposes within the period of 7 years ending with the chargeable event.\n(3) The references to the market value of the converted securities in the definition of CMVCS in section 441(6) (amount of gain realised by conversion) are to what would be the market value but for the reduction as a result of the things done as mentioned in subsection (2).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 7 Ch. 3A inserted (16.4.2003 with effect in accordance with Sch. 22 para. 5(2)-(4) of the amending Act) by Finance Act 2003 (c. 14), Sch. 22 para. 5(1)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2003/1/section/446H",
    "retrieved_at": "2026-10-29T09:18:42.395488+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}