Well done to the SC


Didn't find your answer?

For comprehensively and unanimously dismissing these typically rubbish HMRC submissions where they tried to argue black is white basically (with no less than 2 QCs and a junior) re CT deductible employee share options.


One wonders how HMRC were given permission to appeal in the 1st place, given para 3.

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By richard thomas
23rd Mar 2022 17:51

I agree. "Capital" was the best (or least bad) card of a very poor hand. IR & HMRC have never got over Grant & Mars, and were in denial long before that despite Britannia Airways, Herbert Smith and an unpublished City General Commissioners case involving discounting insurance reserves. A lot of pressure was exerted not to define too closely what were the departures allowed in s 42 FA 1998. I know that because I was involved in the later rewrite of it.

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Replying to richard thomas:
By Justin Bryant
23rd Mar 2022 18:07

Interesting and agreed. This SC case has echoes of this other case with rubbish HMRC submissions re tax consequences of accounting treatment in the link below, which I note involved one of their same QCs. The consequence of believing your own propaganda I guess.


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