Berry v Revenue and Customs: FTTTx 29 Dec 2009

FTTTx 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

Citations:

[2009] UKFTT 386 (TC)

Links:

Bailii

Income Tax

Updated: 17 August 2022; Ref: scu.409134