United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> UBS AG v HMRC [2012] UKUT 320 (TCC) (17 September 2012)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2012/320.html
Cite as: [2013] STC 68, [2012] UKUT 320 (TCC)

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UBS AG v HMRC [2012] UKUT 320 (TCC) (17 September 2012)

"Income Tax and NICs: scheme to deliver bonuses in form of shares avoiding income tax and NIC. S18(1) ITEPA Rule 2 – whether employee became "entitled to payment" when amount of bonus determined. Ch 2 Part 7 ITEPA – whether shares were "estricted securities" within s 423(2)(c) – s 429 whether shares were in associated company: s416 control at general meeting level – sham: whether exculpatory provision in Articles a sham. Ramsay- whether on a broad Ramsay approach the scheme was outside Ch 2."

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