A non-resident employee had been given share options exercisable at the price of the shares on the New York Stock Exchange at the date of the grant. The Inland Revenue appealed a decision that the option was to be valued as at the date of grant, rather than at the time it was exercised.
Held: Appeal dismissed. The Act provided for valuation at the date of the disposal of the asset. In this case the asset was the option, and it was to be valued at the date of the grant. The exercise of the option was not a disposal of it, but was to be treated as at one with the grant of the option.
Judges:
Kennedy, Chadwick, Jonathan Parker, LJJ
Citations:
Times 20-Dec-2002, Gazette 13-Mar-2003
Statutes:
Taxation of Chargeable Gains Act 1992 137
Jurisdiction:
England and Wales
Citing:
Appeal from – Mansworth (Inspector of Taxes) v Jelley ChD 20-Mar-2002
The taxpayer had the benefit of option as an employee in his company scheme. He exercised the option and the issue arose as to when the base value of the options were to be valued for capital against tax purposes. The taxpayer argued that they were . .
Cited by:
Appeal To – Mansworth (Inspector of Taxes) v Jelley ChD 20-Mar-2002
The taxpayer had the benefit of option as an employee in his company scheme. He exercised the option and the issue arose as to when the base value of the options were to be valued for capital against tax purposes. The taxpayer argued that they were . .
Lists of cited by and citing cases may be incomplete.
Capital Gains Tax
Updated: 14 June 2022; Ref: scu.178602
