- TCGA 1992, Section 144ZA applies regardless of discretion to satisfy options other than in shares (Davies v Revenue and Customs Commissioners  UKUT 130 (TCC))
- What are the practical implications of this case?
- What was the background?
- What did the court decide?
- Case details
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.
Sign in or take a trial to read the full analysis.
To continue reading this news article, as well as thousands of others like it, sign in to LexisPSL or register for a free trial