[2014] UKFTT 159 (TC)

Judge Rachel Short, Mr Toby Simon

Decision released 7 February 2014

Employment income – Payment under Compromise Agreement – Whether attributable to future right to receive shares – Whether taxable under TCGA 1992, s. 22 – Held – Contingent right to be offered shares in the future not an asset for CGT purposes – Whole of sum taxable as employment income – Appeal dismissed

  The First-tier Tribunal dismissed the taxpayer’s appeal, ruling that a payment under a Compromise Agreement was taxable as employment income and not as a capital gain from the disposal of share rights.


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