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16 November 2009
Yellow (TC207)
Between April 1997 and April 2000, options over shares in Green were granted by the Blue Employee Benefit Trust to individuals working for the Blue Group.
It was agreed that some of those individuals had been seconded to Blue from Yellow.
HMRC issued proceedings against Blue in December 2003. These proceedings were adjourned.
In March 2009, HMRC issued decisions against Yellow in respect of the same National Insurance liabilities as were covered in Blue TC109 (see Needless delay).
The company appealed, but HMRC applied to have the Blue and Yellow appeals heard together.
The tribunal agreed that the appeal should be joined with the Blue appeal, so they could be heard together.
