The taxpayers sought relief after giving shares in a company to another company owned by themselves. The taxpayers appealed refusal of hold over relief in respect of chargeable gains. Held: The holdings in the recipient company made the companies connected with each other. The section was plainly intended to provide this result, even though that … Continue reading Foulser and Another v Macdougall: CA 17 Jan 2007
The taxpayer company entered into an arrangement in which shares were purchased by a company based in Ireland and resold. A claim was made for holdover relief. Held: The scheme failed. The restriction imposed did not infringe the right of establishment under European law since the company was not restricted from setting up business. It … Continue reading Foulser and Another v HM Inspector of Taxes: ChD 20 Dec 2005
The Revenue appealed dismissal of its claim for assessment to tax of distributions received from taxpayers units in an enterprise zone property.
Held: The appeal failed. Legislation had since prevented 100% capital allowance claims. . .
