Stephen Davies v The Commissioners for HM Revenue and Customs: [2018] UKUT 0130 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Zacaroli and Judge Berner on 30 April 2018.

Read the full decision in Stephen Davies v The Commissioners for HM Revenue and Customs: [2018] UKUT 0130 (TCC).

CAPITAL GAINS TAX – unapproved employee share options – grantor having discretion on exercise of option to satisfy option holder’s entitlement either by transfer of shares or payment of cash – whether s 144ZA TCGA disapplies the market value rule in s 17(1) TCGA.

Published 9 May 2018