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Company A Revealed

Nigel Doran partner in the corporate tax group at Macfarlanes LLP considers the decision in Gray's Timber Products Ltd v HMRC on the taxation of shares sold by employees at more than market value
In March 2007 a single Special Commissioner heard Company A v HMRC SpC 602 which is thought to be the first reported case on the new income tax regime for employment-related securities in ITEPA 2003 Part 7. Specifically the Special Commissioner had to consider whether Chapter 3D of Part 7 (employment-related securities sold for more than market value) applied to impose a charge to income tax on a sale of shares by an employee under the provisions of a shareholders' agreement at a favourable price. He decided that it did. The taxpayer company's appeal against...

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