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J Charman v CRC, Upper Tribunal (Tax and Chancery Chamber), 27 August 2020
The taxpayer was born in the UK. In November 2001 he joined A S Ltd a new insurance entity in Bermuda as its president and chief executive. He was awarded share options which vested in three equal tranches conditional on his continued employment with the company. He was later also awarded restricted shares in Axis Specialty Ltd. As part of an initial public offering his original restricted shares were exchanged for restricted shares in Axis Capital and his options became options over Axis Capital shares.
In March 2008 the taxpayer exercised the options and sold the shares. The taxpayer claimed no UK tax was due on the options because he was not resident in the UK (ITEPA 2003 Pt 7). The First-tier Tribunal decided the taxpayer had acquired a securities option only when each tranche became exercisable as opposed to the date on which the...
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