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TCGA 1992, Section 144ZA applies regardless of discretion to satisfy options other than in shares (Davies v Revenue and Customs Commissioners [2018] UKUT 130 (TCC))

Published on: 10 May 2018
Published by: LexisPSL
  • TCGA 1992, Section 144ZA applies regardless of discretion to satisfy options other than in shares (Davies v Revenue and Customs Commissioners [2018] UKUT 130 (TCC))
  • What are the practical implications of this case?
  • What was the background?
  • What did the court decide?
  • Case details

Article summary

Share Incentives analysis: The Upper Tribunal upheld the FTT’s ruling that Section 144ZA of the Taxation of Chargeable Gains Act 1992 (TCGA 1992)—which disapplies TCGA 1992, s 17 (the market value rule) in relation to an option where the option ‘binds the grantor to sell’—still applies regardless of whether the grantor has a discretion as to whether to settle the share option in cash or shares. or take a trial to read the full analysis.

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