Bonus arrangements were fully taxable: Lynx Forecourt Ltd v HMRC [2024] UKFTT 278 (TC) (27 March 2024) is an appeal that relates to bonus arrangements put in place as far back as 2003. They were designed to exploit the rules which existed at the time under which (broadly) shares which were awarded on a conditional basis only became taxable at the point when the conditions fell away. If as here the shares were structured in a way so that their value was reduced at the point at which the conditions fell away it was possible to deliver a taxable reward where the amount charged to tax was significantly less than the actual value received. This type of arrangement has been litigated before but this one had distinctive features. Nonetheless the FTT decided that on a purposive interpretation of the legislation the conditions which it found had...
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