The Supreme Court has upheld the unanimous decisions of the Court of Appeal and tax tribunals that accounting charges associated with employee share options were deductible when calculating trading profits. Subsequent legislation has made clear that no deduction would now be available in the particular circumstances considered by the Supreme Court, although the decision will be welcomed by those other employers still disputing the availability of relief in respect of lapsed employee share options in periods that ended prior to 20 March 2013. The decision is also of more general importance because of the guidance it provides on a number of fundamental questions around how companies should calculate their taxable trading profits and considers the increasingly relevant question of the interpretation of rewritten tax legislation.
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The Supreme Court has upheld the unanimous decisions of the Court of Appeal and tax tribunals that accounting charges associated with employee share options were deductible when calculating trading profits. Subsequent legislation has made clear that no deduction would now be available in the particular circumstances considered by the Supreme Court, although the decision will be welcomed by those other employers still disputing the availability of relief in respect of lapsed employee share options in periods that ended prior to 20 March 2013. The decision is also of more general importance because of the guidance it provides on a number of fundamental questions around how companies should calculate their taxable trading profits and considers the increasingly relevant question of the interpretation of rewritten tax legislation.
If you are not a subscriber, subscribe now to read this content.
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