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IAIN MACLEOD reports on a conversation about ITEPA 2003, s 222
KEY POINTS
- ITEPA 2003 s 222 applies mechanistically.
- The employee has 90 days to make good the tax to the employer.
- Cases challenging the application of s 222.
- Make sure PAYE and NI position is up to date.
- Does Parade Park Hotel offer hope?
A recent Special Commissioners’ decision JE Chilcott RI Griffiths and Evolution Group Services Ltd (SpC 727) concerned a dispute over the application of PAYE on share option gains.
This has caused some interest as the following conversation shows. Andy Goodman’s article Sharing the burden also touched on this topic.
The parties are AY an accountant and JR financial controller of Submax Ltd which is a UK resident client and a wholly owned subsidiary of US quoted Submax Inc.
JR...
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