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Another brick in the pond
KEY POINTS
- Tax treatment of unapproved share options throw into disarray in 2003.
- HMRC’s initial interpretation was overridden by Revenue and Customs Brief 30/09 in May 2009.
- Different groups of taxpayers were afforded different treatment of losses.
- Court of Appeal in CRC v Hely Hutchinson has said this is not an abuse of HMRC’s power.
When Colin Jelley exercised unapproved employee share options in 1989 and 1991 he can hardly have anticipated that he would set off a chain of events which more than 25 years later is still causing massive waves in the tax system. The Court of Appeal has recently thrown the latest – but...
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