Elevenses with Devereux - Charman v HMRC: the scope and application of the “by reason of employment” test
Akash Nawbatt QC and Kate Balmer discuss the recent decisions of the Upper Tribunal in Charman v HMRC and Vermilion v HMRC. In particular they consider (i) the meaning of the “by reason of employment” test; (ii) whether there is any material difference with the “from” employment emoluments test; (iii) the application of the “by reason of employment” test where there is one more than one operative cause; and (iv) the correct approach to identifying the date when share options are acquired.
This webinar was broadcast on 4 December 2020.
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Disclaimer: These webinars contain the personal views of the barristers involved at the date of broadcast on topics of general interest. They should not be relied upon as constituting legal advice.
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