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Mansworth v Jelley and trust in HMRC

Very broadly the current Mansworth v Jelley controversy turns on a change of HMRC stance on allowable deductions when preparing the CGT computation for shares acquired before 10 April 2003 by exercising employee share options.

The January 2003 Inland Revenue guidance stated clearly that where shares were acquired via employee share options the CGT acquisition cost of such shares was:

  • the market value at the time the option was exercised; plus
  • any amount charged to income tax on the exercise.

In effect this meant a double deduction. HMRC stood by this analysis in the face of significant criticism from commentators and the HMRC attitude meant that it became general practice to prepare computations...

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