UBS AG and DB Group Services (UK) Limited v 皇冠体育app Commissioners for HM Revenue and Customs: [2012] UKUT 320 (TCC)
Upper Tribunal Tax & Chancery decision of Mr Justice Henderson and Judge Hellier on 17 September 2012.
Read the full decision in .
Income Tax and NICs: scheme to deliver bonuses in form of shares avoiding income tax and NIC. S18(1) ITEPA Rule 2鈥� whether employee became 鈥渆ntitled to payment鈥� when amount of bonus determined. Ch 2 Part 7 ITEPA 鈥� whether shares were 鈥渞estricted securities鈥� within s 423(2)(c) 鈥� s 429 whether shares were in associated company: s416 control at general meeting level 鈥� sham: whether exculpatory provision in Articles a sham. Ramsay- whether on a broad Ramsay approach the scheme was outside Ch 2.
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Published 1 December 2016