Search Results for: Taxation of Chargeable Gains Act 1992 115

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Weston v Garnett (Inspector of Taxes): ChD 25 Jun 2004

The taxpayer entered into a scheme for the issue and disposal of corporate loans. He appealed a finding that the loans were caught by section 115 which disallowed exemption because they did not represent a normal commercial loan. Held: It was a requirement that the debt ‘has at all times represented a normal commercial loan’, … Continue reading Weston v Garnett (Inspector of Taxes): ChD 25 Jun 2004

Hancock and Another v Revenue and Customs: SC 22 May 2019

The taxpayers sold their shares in return for loan notes in the form of mixed qualifying (QCB) and non qualifying corporate bonds (Non-QCB) within section 115 of the 1992 Act. Gains on the disposal of QCB would be exempt from CGT. These were then converted to QCBs. The court was asked as to their chargeability … Continue reading Hancock and Another v Revenue and Customs: SC 22 May 2019

W T Ramsay Ltd v Inland Revenue Commissioners: HL 12 Mar 1981

The taxpayers used schemes to create allowable losses, and now appealed assessment to tax. The schemes involved a series of transactions none of which were a sham, but which had the effect of cancelling each other out. Held: If the true nature of the transactions could be seen by looking at them all together, then … Continue reading W T Ramsay Ltd v Inland Revenue Commissioners: HL 12 Mar 1981

Hancock and Another v Revenue and Customs: CA 25 May 2017

interaction of the rules which relate to corporate reorganisations and those which relate to qualifying corporate bonds Judges: Lewison, Kitchen, Floyd LJJ Citations: [2017] EWCA Civ 198, [2017] 1 WLR 4717, [2017] WLR(D) 363, [2017] STC 1496, [2017] STI 1325, [2017] BTC 14 Links: Bailii, WLRD Statutes: Taxation of Chargeable Gains Act 1992 Jurisdiction: England … Continue reading Hancock and Another v Revenue and Customs: CA 25 May 2017

Weston v Garnett (HM Inspector of Taxes): CA 16 Jun 2005

Convertible loan notes had been issued as a channel for future gains. Held: The loan notes were not a normal commercial loan as defined in Schedule 18 to the 1988 Act, and therefore did not fall within the section so as to allow qualification for exemption from liability to tax. The conditions relating to ‘normal … Continue reading Weston v Garnett (HM Inspector of Taxes): CA 16 Jun 2005