UBS AG v HMRC [2012] UKUT 320 (TCC) (17 September 2012)
"Income Tax and NICs: scheme to deliver bonuses in form of shares avoiding income tax and NIC. S18(1) ITEPA Rule 2 – whether employee became "entitled to payment" when amount of bonus determined. Ch 2 Part 7 ITEPA – whether shares were "estricted securities" within s 423(2)(c) – s 429 whether shares were in associated company: s416 control at general meeting level – sham: whether exculpatory provision in Articles a sham. Ramsay- whether on a broad Ramsay approach the scheme was outside Ch 2."
A HTML version of this file is not available click here or view below the pdf version : 320.pdf
