I was pleased to speak recently at The Tax Journal's new Tax Practitioners' Group where I was asked why HMRC had changed its view on an aspect of the capital gains tax (CGT) treatment of employee share options and why we are treating taxpayers differently depending on whether their cases were open or closed.
By way of background when we lost the Mansworth v Jelley employee share option case in 2002 we published guidance in January 2003 to reflect our understanding of that decision. Our understanding at the time was that people could obtain a 'double deduction' for the amount charged to income tax on the option gain when calculating their CGT liability on the subsequent disposal of shares. Finance Act 2003 changed the...
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I was pleased to speak recently at The Tax Journal's new Tax Practitioners' Group where I was asked why HMRC had changed its view on an aspect of the capital gains tax (CGT) treatment of employee share options and why we are treating taxpayers differently depending on whether their cases were open or closed.
By way of background when we lost the Mansworth v Jelley employee share option case in 2002 we published guidance in January 2003 to reflect our understanding of that decision. Our understanding at the time was that people could obtain a 'double deduction' for the amount charged to income tax on the option gain when calculating their CGT liability on the subsequent disposal of shares. Finance Act 2003 changed the...
If you are not a subscriber, subscribe now to read this content.
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