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Jones Bros Ruthin (Civil Engineering) Co Ltd and another v HMRC

In Jones Bros Ruthin (Civil Engineering) Co Ltd and another v HMRC [2022] UKFTT 26 (TC) (20 January 2022) the FTT dismissed the taxpayers’ appeals concerning an award of bonuses under contracts for differences for the purposes of ITEPA 2003 Part 7. The FTT reached this decision by adopting a purposive approach on a realistic view of the facts.

These appeals by Jones Bros Ruthin (Civil Engineering) Co Ltd and Britannia Hotels Ltd were heard together because they raised similar questions of fact and law. A number of similar appeals were stayed pending the outcome of these two test cases.

The appellants participated in arrangements known as a growth securities ownership plan (GSOP) implemented in 2010. The arrangement involved employees entering into a ‘contract for differences’ under which the employer paid a sum to the employee if profits reached a specified threshold but the employee had to pay the employer if...

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