Stephen Davies v The Commissioners for HM Revenue and Customs: [2018] UKUT 0130 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Zacaroli and Judge Berner on 30 April 2018.
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CAPITAL GAINS TAX 鈥� unapproved employee share options 鈥� grantor having discretion on exercise of option to satisfy option holder鈥檚 entitlement either by transfer of shares or payment of cash 鈥� whether s 144ZA TCGA disapplies the market value rule in s 17(1) TCGA.
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Published 9 May 2018