HMRC Can't Revive Tax Bill Over Share Option Treatment

Law360, London (April 9, 2019, 8:30 PM BST) -- A London tribunal has dismissed an appeal brought by the U.K.’s tax authority over NCL Investment Ltd.’s accounting treatment of its employee benefits, siding with the financial firm’s position that it was entitled to claim the tax relief in dispute.

The Upper Tribunal handed down its ruling Monday, upholding the First-Tier Tribunal’s decision from June 2017 that debits recorded in the firm’s financial accounts under international financial reporting standards are a deductible trading expense.

HM Revenue and Customs was seeking to uphold closure notices it had issued against NCL Investments and its parent company, Smith & Williamson Holdings Ltd., over their...

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