Before a contentious appeal that involves a question of valuation of employment-related securities is heard, the case should be reviewed to ensure that:
- the grounds for considering that Income Tax liability arises is firm, and
- the amounts involved are not trivial.
The papers may then be submitted to the Employee Shares & Securities Unit, to consider whether the Solicitors should be asked to represent HMRC at the tribunal.
For guidance on working tribunal cases, see the Appeals, reviews and tribunals guidance, ARTG.