ERSM220120 - Valuation Issues

Contentious appeal

Before a contentious appeal that involves a question of valuation of employment-related securities is heard, the case should be reviewed to ensure that:

• the grounds for considering that Income Tax liability arises is firm, and
• the amounts involved are not trivial.

The papers may then be submitted to the Employee Shares & Securities Unit, to consider whether the Board's Solicitor should be asked to represent HMRC at the hearing.