The Supreme Court has given the taxpayer permission to appeal in HMRC v PA Holdings Limited. The case concerns the tax treatment of dividends paid to employees through a share plan. The Court of Appeal ruled in favour of HMRC, holding that the dividend payments were earnings. The Tribunal had previously held that the dividends were both distributions and earnings, but that for income tax the Schedule F charge took priority.
See http://www.bailii.org/ew/cases/EWCA/Civ/2011/1414.html for the Court of Appeal’s decision.