Legal News

Commercially irrelevant provisions do not make securities 'restricted' (Cyclops and Graceland v HMRC)

Published on: 20 July 2016
Published by: LexisPSL
  • 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
  • Valuation
  • What should tax lawyers take note of?

Article summary

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. or take a trial to read the full analysis.

Popular documents