Employment Related Securities
Employment Related Securities disputes arise where HMRC challenges the valuation placed on shares or options at grant, vesting, or exercise. Growth share arrangements, hurdle structures, and restricted share plans are common areas of dispute.
Tax expert witnesses provide independent analysis of market value at the relevant date, assessing commercial restrictions on shares and whether HMRC's valuation methodology is appropriate.
s431 election disputes require expert evidence on the unrestricted market value at acquisition and the correct tax treatment of the overall arrangement.
| Aspect | Detail |
|---|---|
| Valuation date | Market value at grant, vesting, or exercise as relevant |
| Restrictions | Analysis of commercial restrictions affecting value |
| s431 elections | Assessment of unrestricted market value at acquisition |
| ITEPA analysis | Correct tax treatment of share and option arrangements |
Frequently Asked Questions
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