In KA Rogers v HMRC (TC01036 – 11 April) a UK company (SU) which was a subsidiary of an overseas company (SN) recruited a senior employee (R) in 1998.
R subsequently became SU’s managing director and in 1996 he became its chairman. In 2001 he was awarded a 9% shareholding in SN for a nominal consideration of $1 per share. He left SU in 2003 when part of its business was taken over by a competitor.
HMRC subsequently issued an assessment on R charging tax on the basis that the transfer of the shareholding in SN was an emolument deriving from his employment with SU.
R appealed contending that the transfer should be treated as a non-taxable gift or testimonial applying the principles laid down by Sellers LJ in the...
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In KA Rogers v HMRC (TC01036 – 11 April) a UK company (SU) which was a subsidiary of an overseas company (SN) recruited a senior employee (R) in 1998.
R subsequently became SU’s managing director and in 1996 he became its chairman. In 2001 he was awarded a 9% shareholding in SN for a nominal consideration of $1 per share. He left SU in 2003 when part of its business was taken over by a competitor.
HMRC subsequently issued an assessment on R charging tax on the basis that the transfer of the shareholding in SN was an emolument deriving from his employment with SU.
R appealed contending that the transfer should be treated as a non-taxable gift or testimonial applying the principles laid down by Sellers LJ in the...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
