No corporation tax relief for option gain because the option was not granted by reason of employment as a matter of fact (First-tier Tribunal) | Practical Law

No corporation tax relief for option gain because the option was not granted by reason of employment as a matter of fact (First-tier Tribunal) | Practical Law

The First-tier Tribunal has decided that, for the purposes of Schedule 23 of Finance Act 2003, no corporation tax deduction is available for gains realised on the exercise of an option granted to an employee or former employee if, as a matter of fact, the option was not granted by reason of employment. (Metso Paper Bender Forrest Limited and Metso Paper Bender Machine Services Limited v HMRC [2013] UKFTT 674 (TC).)

No corporation tax relief for option gain because the option was not granted by reason of employment as a matter of fact (First-tier Tribunal)

by Practical Law Share Schemes & Incentives
Published on 02 Dec 2013 • United Kingdom
The First-tier Tribunal has decided that, for the purposes of Schedule 23 of Finance Act 2003, no corporation tax deduction is available for gains realised on the exercise of an option granted to an employee or former employee if, as a matter of fact, the option was not granted by reason of employment. (Metso Paper Bender Forrest Limited and Metso Paper Bender Machine Services Limited v HMRC [2013] UKFTT 674 (TC).)