- Deferred shares—relief for entrepreneurs?
- Original news
- What were the facts of this case?
- What did the taxpayer argue?
- How did HMRC respond?
- What did the FTT decide?
- Why did the taxpayer’s purposive approach arguments fail?
- How does this decision impact companies whose share capital has been carefully structured to allow individuals to benefit from ER?
- Does the decision have ramifications beyond ER?
- What can practitioners learn from this case?
Tax analysis: Does a recent appeal tribunal victory for HMRC give the seal of approval to a common tax planning strategy for entrepreneurs? Colin Kendon, partner and head of the employee incentives and benefits team at Bird & Bird LLP, considers the recent First-tier Tribunal (FTT) decision in Alan Castledine v HMRC.
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