Nigel Doran partner in the corporate tax group at Macfarlanes considers the decision in Company A v HMRC on the taxation of shares sold by employees at an overvalue
We have over one hundred years of case law on the valuation of assets of one kind or another predominantly in the context of estate duty but until recently nothing on how the principles in those cases apply in the very different context of the valuation of shares held by employees under Part 7 of ITEPA 2003. In what is thought to be the first reported decision on a Part 7 charging provision Company A v HMRC SpC 602 the Special Commissioner had to consider whether Chapter 3D (employment-related securities sold for more than market value) applied to a...
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Nigel Doran partner in the corporate tax group at Macfarlanes considers the decision in Company A v HMRC on the taxation of shares sold by employees at an overvalue
We have over one hundred years of case law on the valuation of assets of one kind or another predominantly in the context of estate duty but until recently nothing on how the principles in those cases apply in the very different context of the valuation of shares held by employees under Part 7 of ITEPA 2003. In what is thought to be the first reported decision on a Part 7 charging provision Company A v HMRC SpC 602 the Special Commissioner had to consider whether Chapter 3D (employment-related securities sold for more than market value) applied to a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
