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NCL Investments and another v HMRC

In NCL Investments and another v HMRC [2017] UKFTT 495 (14 June 2017) the FTT found that share options which had been granted by the parent of a group to employees of its subsidiaries were deductible trading expenses.

The appellant companies were members of a group whose ultimate parent was SWHL. The group provided tax and accountancy services as well as wealth management services. The appellant companies employed staff which they made available to other companies in the group in return for a fee. SWHL had granted share options under various schemes to employees of the appellants and many had lapsed. Whenever employees of the appellants were granted share options they paid SWHL an amount equal to the option; however HMRC had refused the corresponding deductions.

The first issue was whether the debits had been incurred wholly and exclusively for the purpose of...

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