UBS AG and DB Group Services (UK) Limited v The Commissioners for HM Revenue and Customs: [2012] UKUT 320 (TCC)

Upper Tribunal Tax & Chancery decision of Mr Justice Henderson and Judge Hellier on 17 September 2012.

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
1 December 2016
Category:
Tax
Release date:
17 September 2012

Read the full decision in .

Income Tax and NICs: scheme to deliver bonuses in form of shares avoiding income tax and NIC. S18(1) ITEPA Rule 2鈥� whether employee became 鈥渆ntitled to payment鈥� when amount of bonus determined. Ch 2 Part 7 ITEPA 鈥� whether shares were 鈥渞estricted securities鈥� within s 423(2)(c) 鈥� s 429 whether shares were in associated company: s416 control at general meeting level 鈥� sham: whether exculpatory provision in Articles a sham. Ramsay- whether on a broad Ramsay approach the scheme was outside Ch 2.

Updates to this page

Published 1 December 2016