UT (Tax & Chancery) UT-2024-000088 - [2025] UKUT 00374 (TCC)

UT (Tax & Chancery) Case Number: UT-2024-000088

The Rolls Building, London

Income Tax – Payment made to Appellant pursuant to long-term incentive plan – Payment received after Appellant had ceased employment and become non-UK resident – whether Payment within s.62 ITEPA 2003 – Whether Payment attributable to overseas part of split Year under ss.15-16 ITEPA 2003

Judgment given on:: 31 October 2025

Before

THE HONOURABLE MR JUSTICE FOXTON

JUDGE ANNE REDSTON

Between

MICHAEL SAUNDERS

Appellant

and

THE COMMISSIONERS FOR

HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Michael Firth KC, instructed by the Appellant

For the Respondents: Georgia Hicks of Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs

DECISION