The WLR Daily case summaries
[2021] WLR(D) 613
Court of Appeal
Charman v Revenue and Customs Comrs
[2021] EWCA Civ 1804
2021 Nov 17–18; Dec 3
Green, Arnold, Snowden LJJ
Revenue— Income tax— Employment— Perquisite— Option to purchase shares— Share purchase option agreement appended to taxpayer’s contract of employment— Taxpayer resident in United Kingdom at time option granted— Taxpayer no longer resident in United Kingdom at time option vesting— Taxpayer subsequently exercising option— Revenue issuing closure notice— Whether taxpayer resident in United Kingdom “at time of acquisition”— Whether option “acquired” at time of grant or at time of vesting— Whether taxpayer liable to pay tax on sums realised from exercise of option—
Income Tax (Earnings and Pensions) Act 2003 (c 1), ss 420(8), 474(1)