Turning to Jelley…

Tax column: AT considers the implications - some helpful, some not - of the share option decision in Mansworth v Jelley and the Revenue’s interpretation of the case

Of the hundreds of tax cases heard every year, few make a lasting impression. But on 12 December 2002, the Court of Appeal delivered its judgement on Mansworth v Jelley. This, and the subsequent Inland Revenue interpretation note, has become a talking point for anyone involved in tax.

Generally, if an employee exercises an unapproved share option (or makes an...

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