References: [2011] UKUT 81 (TCC)
Links: Bailii
UTTC Tax avoidance – Income Tax – Discounts – Gilt strips – Computation of loss -Scheme designed to create excess of amount paid for the strip over the amount payable on transfer – Excess represented by ‘premium’ for grant by taxpayer of call option – Whether option price to be added back in determining amount payable on the taxpayer’s transfer – Yes – Appeal dismissed – Para 14A Sch 13 FA 1996.
