Grays Timber Products Ltd v Revenue and Customs Commissioners [2010] UKSC 4; [ 2010] WLR (D) 21
“In assessing whether employment-related securities had been disposed of for a consideration which exceeded their ‘market value’, so as to occasion a charge to income tax, it was necessary to postulate a notional sale between a hypothetical vendor and purchaser, with the personal characteristics of the actual vendor, such as his right under a subscription agreement to a disproportionately large part of the consideration paid, being ignored.”
WLR Daily, 3rd February 2010
Source: www.lawreports.co.uk
Please note once a case has been reported in one of the ICLR series the corresponding WLR Daily summary is removed.