Share Scheme Manual - SSM7.23

Charge to tax disputed

(Previously SE2998)

When an event has occurred which might result in a charge to tax under FA88/S78 - FA88/S80 the company may

• contend that the share values are not such as to result in a charge, or

• dispute that there is a potentially chargeable occasion.

When this happens Shares Valuation Division should be asked to give an informal opinion on values at an early stage. This will help to ensure that SA returns can be completed on an agreed basis.