References: [2010] UKUT 114 (TCC), [2010] STI 2112, [2010] BTC 1513, [2010] STC 1849
Links: Bailii
Coram: Avery Jones CBE
UTTC CAPITAL GAINS TAX – exchange of shares for debentures – whether TCGA 1992 s 137 applies to each shareholder separately – no – whether Special Commissioner entitled to conclude that the main purpose was tax avoidance – yes – appeal dismissed
Statutes: Taxation of Chargeable Gains Act 1992 137