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

In January 2017, Mr Saunders received a payment of £1,236,956 (“the Payment”) from Hibernia Atlantic UK Ltd (“HAUKL”), his former employer, pursuant to a grant of stock appreciation rights (“SARs”) awarded to him by HAUKL’s parent company on 4 April 2013. HMRC determined that the Payment constituted taxable income in the UK.

Mr Saunders appealed against the decision to the First Tier Tribunal (“FTT”). On 2 April 2024, the FTT (Judge Jeanette Zaman and Tribunal Member Mr Mohammed Farooq) dismissed that appeal (“the Decision”). Mr Saunders was given permission to appeal to the Upper Tribunal against the Decision.