Income tax – tax avoidance scheme involving ‘gifts to charity’ relief – s 587B ICTA – pre-existing option arrangements, secured by charges, for securities in question to be acquired from charity for 1% of value following charity’s receipt of them – whether Appellant had disposed of whole of the beneficial interest in the securities to the charity – held no – effect of composite transaction was that the disposal was, as to 99% of the value, to the Appellant’s own family trust – additionally, any disposal to the charity was ‘by way of a bargain made at arm’s length’ – s587B(1) therefore not satisfied – appeal dismissed
Citations:
[2014] UKFTT 433 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 12 September 2022; Ref: scu.526813