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Shares to reflect restrictions

21 September 2015
Issue: 4517 / Categories: Tax cases , Companies
Lars Sjumarken (TC4557)
The taxpayer was made redundant from the London branch of BNP Paribas in October 2005. Under the terms of his compromise agreement his shares in the bank’s share incentive plan (SIP) and cash from its cash incentive plan (CIP) were released.
An issue arose on whether the SIP and CIP were tax-approved plans so that the shares and cash were exempt from tax and National Insurance. 
In a hearing before the First-tier Tribunal (reported in Taxation 16 June 2011) the judge found that the evidence against the plans being tax approved was “overwhelming” and dismissed the appeal. The case was reheard because of a “procedural irregularity”.
The parties now agreed that neither the SIP nor the CIP were approved schemes. The dispute instead concerned the correct valuation of the...

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