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.
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