In January 2022 HMRC was successful at the First-tier Tribunal in the cases of Jones Bros Ruthin (Civil Engineering) Co Ltd and Britannia Hotels Ltd which involved a Growth Securities Ownership Plan (“GSOP”). Read our analysis of the case here.
Recent developments
In March 2022 HMRC released Spotlight 59 which specifically relates to GSOP’s - Employee Bonus Schemes: Growth Securities Ownership Plan (GOSP) tax avoidance and similar schemes update (Spotlight 59) - GOV.UK (www.gov.uk). The Spotlight notes the First-tier Tribunal decided that the two appeal cases should proceed as lead cases, with all similar appeals being put on hold pending a decision.
We are not aware either taxpayer has appealed to the Upper Tribunal.
Settling if you have used a similar GSOP
At BDO our Tax Dispute Resolution team has an in-depth understanding of HMRC’s approach to settling tax avoidance arrangements and has significant experience in helping clients resolve tax issues.
If you have participated in a GSOP arrangement and want to consider the options available, which includes settlement with HMRC, please contact our tax enquiry resolution service for further information or assistance or get in touch with Dawn Register or Richard Philson .
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