An Employee v Revenue and Customs: SCIT 19 Mar 2008

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).
[2008] UKSPC SPC00673
Bailii
Taxes Management Act 1979 29(4) 29(5), Income and Corporation Taxes Act 1988 135(1)
England and Wales

Updated: 08 March 2021; Ref: scu.267758