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HMRC internal manual

Employment Related Securities Manual

HM Revenue & Customs
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Valuation Issues

Contentious appeal

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.