KEY POINTS
- The meaning of ‘market value’.
- Restricted securities offered instead of a bonus.
- Schedule F versus Schedule E.
- Share schemes must be implemented with care.
You wait ages for a bus and then three turn up at once; the employment-related securities rules in ITEPA 2003 Part 7 are similar in one respect.
Until recently there had been a dearth of input from the courts on some quite complicated issues. But in the past year or two a succession of cases has had a bearing on this legislation even if indirectly.
First there was Gray’s Timber Products Limited v CRC [2010] STC 782 which concerned charges under Part 7 Chapter 3D ‘Securities disposed of for more than market value’.
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