In Vermilion Holdings Ltd v HMRC [2021] CSIH 45 (20 August 2021) is a majority decision of the Court of Session (Inner House) to reinstate the FTT decision that the grant of a replacement option did not fall within ITEPA 2003 s 471 and therefore was not an employment-related securities option. The original option was issued by Vermilion Holdings Ltd to a consultant company in payment for corporate advisory services it had received. There was no real link between the employment and the right or opportunity to acquire the replacement option so the deeming provision in s 471(3) was not triggered. Read the decision.
In G C Field & Sons Ltd and others v HMRC (TC/2018/06225) (19 August 2021) the taxpayers had used an SDLT planning scheme which is now accepted to be ineffective. HMRC argued it was entitled...
