Christopher Snell authors case analysis for LexisNexis (Commissioners for HMRC v Vermilion Holdings Ltd)
Christopher Snell provides a Share Incentives analysis on a recent case held before the Supreme Court, where a director exercising a securities option faced taxation of the gained amount as employment-related income rather than capital gains. The court, guided by the key test in section 471(3) of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), emphasised that if the securities option was granted by the employer, the resulting gain should be taxed as employment income. Chris delves into the details of this significant ruling, shedding light on the implications for share incentives in the corporate landscape.