(1) Subject to this section, where, in respect of or by reference to any of a participant's shares, the trustees become or the participant becomes entitled, before the release date, to receive any money or money's worth (in this section referred to as a "capital receipt"), the participant shall be chargeable to income tax under Schedule E for the year of assessment in which the entitlement arises on the appropriate percentage (determined as at the time when the trustees become or the participant becomes so entitled) of the amount or value of the receipt.
(2) Money or money's worth shall not be a capital receipt for the purposes of this section if or, as the case may be, to the extent that -
(a) it constitutes income in the hands of the recipient for the purposes of income tax,
(b) it consists of the proceeds of a disposal within section 512, or
(c) it consists of new shares within the meaning of section 514.
(3) Where, pursuant to a direction given by or on behalf of the participant or
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