SCIT SHARE OPTIONS – unapproved scheme – gains by employee – whether charge to income tax arises when options exercised but shares not sold – yes – ICTA 1988 s 135(1).
ASSESSMENT – power to raise assessment – whether loss of tax attributable to negligent conduct on the part of the Appellant or the person acting on his behalf – yes – whether at the relevant time the Revenue could not have been reasonably expected to be aware of the loss of tax – yes – appeal dismissed – TMA 1970 s 29 (4) and (5).
Citations:
[2008] UKSPC SPC00673
Links:
Statutes:
Taxes Management Act 1979 29(4) 29(5), Income and Corporation Taxes Act 1988 135(1)
Jurisdiction:
England and Wales
Income Tax
Updated: 07 September 2022; Ref: scu.267758
