Thomas Dalby (Gabelle) reviews an Upper Tribunal decision on CT deductions for share options.
In a judgment handed down on 8 April 2019 the Upper Tribunal (UT) rejected HMRC’s appeal in HMRC vNCL Investments Ltd Smith & Williamson Corporate Services Ltd [2019] UKUT 111 (TCC).
Because FA 1998 mandated that a company’s accounts form the basis for its corporation tax calculations the question then arises as to whether accounting charges that do not have an actual monetary basis should be deductible.
The accounting rules
In this case the accounting standards governing the grant of employee share options and other types of share awards are set out in IFRS 2 (this accounting standard was adopted with a few minor amendments as FRS 20 and was incorporated into FRS 102 at section 26).
Under these...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Thomas Dalby (Gabelle) reviews an Upper Tribunal decision on CT deductions for share options.
In a judgment handed down on 8 April 2019 the Upper Tribunal (UT) rejected HMRC’s appeal in HMRC vNCL Investments Ltd Smith & Williamson Corporate Services Ltd [2019] UKUT 111 (TCC).
Because FA 1998 mandated that a company’s accounts form the basis for its corporation tax calculations the question then arises as to whether accounting charges that do not have an actual monetary basis should be deductible.
The accounting rules
In this case the accounting standards governing the grant of employee share options and other types of share awards are set out in IFRS 2 (this accounting standard was adopted with a few minor amendments as FRS 20 and was incorporated into FRS 102 at section 26).
Under these...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
