Commissioners for His Majesty’s Revenue and Customs v Vermilion Holdings Limited – UKSCBlog
In this post, Jack Prytherch, Of Counsel in the Tax team at CMS, previews the decision awaited from the Supreme Court in Commissioners for His Majesty’s Revenue and Customs v Vermilion Holdings Limited. The appeal was heard by the Supreme Court on 7 February 2023.
The Supreme Court was asked to consider whether the grant of an option to acquire share capital in the appellant (“VHL”) to one of its directors should be treated as an employment-related securities option for the purposes of section 471 of the Income Tax (Earnings and Pensions) Act 2003 (“ITEPA”),


