John Charman and The Commissioners for HM Revenue and Customs: [2020] UKUT 0253 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Falk and Judge Thomas Scott on 27 August 2020.

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INCOME TAX whether a right to acquire securities arose at time when share option was granted or only when it vested held when granted whether shares issued on share-for-share exchange were acquired as a director or employee where original shares were so acquired held yes.

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Published 1 September 2020