Well done to the SC

https://www.bailii.org/uk/cases/UKSC/2022/9.html

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.

https://www.bailii.org/uk/cases/UKSC/2022/9.html

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have never got over Grant & Mars, and were in denial long before that despite Britannia Airways, Herbert Smith and an unpublished City General Commissioners case involving discounting insurance reserves.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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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.

https://www.accountingweb.co.uk/any-answers/hmrc-do-not-understand-doubl...

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