The Supreme Court gave its opinion last week in Grays Timber Products Ltd v Revenue and Customs (Scotland) [2010] UKSC 4 - see here (html) or here (pdf). The Supreme Court summary of the decision is available here (pdf). The opinion contains some brief discussion of shareholder rights and the extent to which the rights attaching to shares might be found in documents other than the articles of association. A summary of the decision has been provided by the ICLR as part of its WLR Daily Service, the headnote for which reads:
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".
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