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In this podcast, Emma Game and Tanja Velling discuss the Supreme Court’s decision in Vermilion considering whether a particular securities option was employment-related, the Court of Appeal’s decision in Delinian (formerly Euromoney) on the purpose test in the capital gains tax reorganisation rules, and the Upper Tribunal’s decision in Refinitiv, a judicial review case where the taxpayers argued that a diverted profits tax notice was inconsistent with an advance pricing agreement.
By Slaughter and MayIn this podcast, Emma Game and Tanja Velling discuss the Supreme Court’s decision in Vermilion considering whether a particular securities option was employment-related, the Court of Appeal’s decision in Delinian (formerly Euromoney) on the purpose test in the capital gains tax reorganisation rules, and the Upper Tribunal’s decision in Refinitiv, a judicial review case where the taxpayers argued that a diverted profits tax notice was inconsistent with an advance pricing agreement.