CAPITAL GAINS TAX – principal private residence relief – whether appellant occupied property for the purposes of section 222 Taxation of Chargeable Gains Act 1992 – appeal dismissed Citations: [2019] UKFTT 704 (TC) Links: Bailii Jurisdiction: England and Wales Capital Gains Tax Updated: 20 November 2022; Ref: scu.646909
Capital Gains Tax – s 222 Taxation of Capital Gains Act 1992 – discovery assessment of capital gains on sale of residential property and fixed penalty for failure to include the gains in a self-assessment return – whether principal private residence exemption applies – no – appeal dismissed [2018] UKFTT 770 (TC) Bailii England and … Continue reading Booth v Revenue and Customs (Capital Gains Tax/Taxation of Chargeable Gains : Disposal): FTTTx 21 Dec 2018
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In order to claim relief against Capital Gains tax on the disposal of business assets on retirement, the assets could be disposed of separately, but some connection must be shown to establish that they formed part of the same transaction overall. A . .
substantial shareholding exemption – schedule 7AC Taxation of Chargeable Gains Act 1992 – paragraphs 7 and 15A – whether relief available when the shares have been owned by a company in a group for less than 12 months – no Citations: [2021] UKFTT 69 (TC) Links: Bailii Jurisdiction: England and Wales Capital Gains Tax Updated: … Continue reading M Group Holdings Ltd v Revenue and Customs (Substantial Shareholding Exemption): FTTTx 12 Mar 2021
CAPITAL GAINS TAX – entrepreneurs relief – section 169 whether J Taxation of Chargeable Gains Tax Act 1992 – trust business assets – shares – settlement business assets – whether ‘qualifying beneficiary’ must be a qualifying beneficiary throughout a period of one year ending not earlier than three years before the date of disposal – … Continue reading The Quentin Skinner 2005 Settlement L and Others v Revenue and Customs (Income Tax/Corporation Tax : Entrepreneurs Relief): FTTTx 6 Aug 2019
Capital Gains Tax – entrepreneurs’ relief – Taxation of Chargeable Gains Act 1992, sections 169I and 169S – whether or not the appellant held at least 5% of the ordinary share capital of the company and at least 5% of the voting rights by virtue of that holding – no – whether or not shares … Continue reading Kavanagh v Revenue and Customs: FTTTx 31 May 2022
FTTTx CAPITAL GAINS TAX – disposal of property used in used car business- entrepreneur’s relief – section 169I Taxation of Chargeable Gains Act 1992- whether cessation of trade – whether disposal within three years of cessation -yes – appeal allowed Citations: [2014] UKFTT 132 (TC) Links: Bailii Jurisdiction: England and Wales Capital Gains Tax Updated: … Continue reading Jeremy Rice v Revenue and Customs: FTTTx 29 Jan 2014
Application of Hastings-Bass Rule F had created two settlements. Distributions were made, but overlooking the effect of section 2(4) of the 2002 Act, creating a large tax liability. P had taken advice on the investment of the proceeds of a damages claim and created a discretionary trust. Unfortunately it was done in such a way … Continue reading Futter and Another v Revenue and Customs; Pitt v Same: SC 9 May 2013
ECJ Judgment – Failure of a Member State to fulfil obligations – Freedom of establishment – Free movement of capital – Articles 49 TFEU and 63 TFEU – Articles 31 and 40 of the EEA Agreement – National tax legislation – Attribution of gains to participators in close companies – Different treatment of resident and … Continue reading Commission v United Kingdom: ECJ 13 Nov 2014
A settlor by will was deemed to have had an interest as funds were passed to a Jersey Trust. The section merely made or allowed that a variation of a will would not be a taxable event in UK law. It had no other effects. A deed of family arrangement . .
The taxpayer company purchased properties to be occupied by other companies within the same group. Having granted leases, they assigned the rental income for the first six years to a bank in return for a capital payment. They then sought relief from . .
A settlor by will was deemed to have had an interest as funds were passed to a Jersey Trust. The section merely made or allowed that a variation of a will would not be a taxable event in UK law. It had no other effects. A deed of family arrangement . .
