CAPITAL GAINS TAX- tax avoidance scheme – whether Appellant’s loan notes were converted to qualifying corporate bonds for the purposes of sections 116 and 117 TCGA 1992 – whether steps taken to reduce the market value of loan notes effective for capital gains tax purposes – purposive construction and the application of the Ramsay principle – error in drafting amendments to loan notes – principles of contractual interpretation – whether HMRC entitled to raise a discovery assessment under section 29 TMA 1970 – whether the officer could reasonably be expected to be aware of the insufficiency – appeal dismissed
[2012] UKFTT 499 (TC), [2012] STI 3236, [2012] SFTD 1264
Bailii
England and Wales
Updated: 27 October 2021; Ref: scu.466071