- Commercially irrelevant provisions do not make securities 'restricted' (Cyclops and Graceland v HMRC)
- Original news
- What was this case about?
- What did the tribunal decide?
- UBS AG and DB Group
- Restricted securities
- What should tax lawyers take note of?
Tax analysis: The First-tier Tax Tribunal (FTT) found the forfeiture provisions contained in loan notes were commercially irrelevant and designed only to secure a tax exemption. As a result, the loan notes were not ‘restricted securities’ for the purposes of ITEPA 2003, s 423, and therefore income tax and NICs were due.
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