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Issue:
4913
/
Categories:
Comment & Analysis
, employee incentives
, ITEPA 2003
, National Insurance
, Income Tax
Let justice decide
Key points
- HMRC v Vermilion Holdings Ltd is a Scottish case concerned with the application of ITEPA 2003 s 471(3).
- The Supreme Court found that a securities option granted by the employer is deemed to be an employment-related securities option and therefore chargeable to income tax and National Insurance contributions.
- The First-Tier Tribunal had initially found in favour of the company while the Upper Tribunal found in favour of HMRC. On appeal by the company the Inner House of the Court of Session by majority (Lords Malcolm and Doherty) held in favour of the company.
CRC v Vermilion Holdings Ltd [2023] UKSC 37 is a Scottish case concerned with ITEPA 2003 s 471 and more specifically the deeming provision in s 471(3) which if it applies brings within the charge to income tax as employment income under...
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