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Do I need to make S431/S430 election?

A brief guide explaining Section 430/431 ITEPA elections, noting when they may be required, how they relate to share issuances for UK tax purposes, and advising users to seek independent tax advice alongside HMRC guidance.

Sam Simpson
Updated 14th April 2026

Whether you or other need to make such an election are very specific to your circumstances - you should take independent advice on this matter.

That said, our articles do detail: No Shares will be allotted to any Employee, Director, prospective Employee or prospective Director who in the opinion of the Board is subject to taxation in the United Kingdom, unless such person has entered into a joint section 431 ITEPA election with the Company if so required by the Board.

More details are available from HMRC directly

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