John Charman and The Commissioners for HM Revenue and Customs: [2020] UKUT 0253 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Falk and Judge Thomas Scott on 27 August 2020.
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INCOME TAX – whether a right to acquire securities arose at time when share option was granted or only when it vested – held when granted – whether shares issued on share-for-share exchange were acquired “as a director or employee” where original shares were so acquired – held yes.
Published 1 September 2020