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Coll and Coll v HM Revenue and Customs: UTTC 5 Mar 2010

UTTC CAPITAL GAINS TAX – exchange of shares for debentures – whether TCGA 1992 s 137 applies to each shareholder separately – no – whether Special Commissioner entitled to conclude that the main purpose was tax avoidance – yes – appeal dismissed Judges: Avery Jones CBE Citations: [2010] UKUT 114 (TCC), [2010] STI 2112, [2010] … Continue reading Coll and Coll v HM Revenue and Customs: UTTC 5 Mar 2010

Coll and Coll v HM Revenue and Customs; UTTC 5 Mar 2010

References: [2010] UKUT 114 (TCC), [2010] STI 2112, [2010] BTC 1513, [2010] STC 1849 Links: Bailii Coram: Avery Jones CBE UTTC CAPITAL GAINS TAX – exchange of shares for debentures – whether TCGA 1992 s 137 applies to each shareholder separately – no – whether Special Commissioner entitled to conclude that the main purpose was … Continue reading Coll and Coll v HM Revenue and Customs; UTTC 5 Mar 2010

Revenue and Customs v Euromoney Institutional Investor Plc: UTTC 29 Jul 2022

CORPORATION TAX – S137 of Taxation of Chargeable Gains Act 1992 – whether exchange of shares part of a scheme or arrangements of which the main purpose, or one of the main purposes, is avoidance of liability to corporation tax – appeal dismissed Citations: [2022] UKUT 205 (TCC) Links: Bailii Jurisdiction: England and Wales Corporation … Continue reading Revenue and Customs v Euromoney Institutional Investor Plc: UTTC 29 Jul 2022

Blum v Revenue and Customs: UTLC 23 Jul 2013

UTLC TAX – Capital Gains Tax – freehold office premises – value as at 31 March 1982 – rental values – value relativities between floors – yield – comparables – value determined at pounds 137,500 – Taxation of Chargeable Gains Act 1992 P R Francis FRICS [2013] UKUT 0304 (LC) Bailii Taxation of Chargeable Gains … Continue reading Blum v Revenue and Customs: UTLC 23 Jul 2013