The parties arranged for the issue of cross options for the purchase of gilts, which would prove when exercised to be very tax effective when a new system of taxing such transaction was in place, and planned losses could be set off against taxable gains elsewhere. The premiums were fixed by market forces, and there was a small risk that an overall loss would arise.
Judges:
Lady Cosgrove And Lord Eassie And Lord President
Citations:
[2003] ScotCS 188, [2003] STC 1035
Links:
Jurisdiction:
Scotland
Cited by:
Appeal from – Inland Revenue Commissioners v Scottish Provident Institution HL 25-Nov-2004
The parties anticipated a change in the system for taxing gains on options to buy or sell bonds and government securities. An option would be purchased before the change and exercised after the change to create losses which could be set off against . .
Cited – RFC 2012 Plc (Formerly The Rangers Football Club Plc) v Advocate General for Scotland SC 5-Jul-2017
The Court was asked whether an employee’s remuneration is taxable as his or her emoluments or earnings when it is paid to a third party in circumstances in which the employee had no prior entitlement to receive it himself or herself.
Held: The . .
Lists of cited by and citing cases may be incomplete.
Capital Gains Tax
Updated: 16 August 2022; Ref: scu.190900
