Income Tax and NICs: scheme to deliver bonuses in form of shares
avoiding income tax and NIC. S18(1) ITEPA Rule 2– whether employee
became “entitled to payment” when amount of bonus determined. Ch 2 Part
7 ITEPA – whether shares were “restricted securities” within s 423(2)(c) – s
429 whether shares were in associated company: s416 control at general
meeting level – sham: whether exculpatory provision in Articles a sham.
Ramsay- whether on a broad Ramsay approach the scheme was outside Ch