Coll and Another v Revenue and Customs: FTTTx 21 Apr 2009

FTTTx CAPITAL GAINS TAX – Disposal of shares for loan notes – whether the exchange formed part of a scheme or arrangements of which the main purpose or one of the main purposes, is avoidance of liability to capital gains tax- Yes – section 137 Taxation of Capital Gains Act 1992 – Appeal dismissed
PENALTY ASSESSMENT – Whether 1997/98 return containing incorrect statement about the status of clearance application was made fraudulently or negligently – made negligently – quantum of penalty reduced from 85 per cent of tax due to 30 per cent – Appeal allowed in part.

Citations:

[2009] UKFTT 61 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Capital Gains Tax

Updated: 30 July 2022; Ref: scu.373601