ACCRUED INCOME SCHEME – short sale of gilts – whether the Appellant ‘becomes and does not cease to be entitled to them on the day’ within s 710(7) TA 1988 – no – accordingly on no day did the nominal value of gilts held by her exceed pounds 5,000 and no charge arises under the accrued income scheme
PRACTICE – Revenue stating its conclusion in the closure notice that Ramsay applied to deny a deduction for manufactured interest – whether it is open to them to abandon the Ramsay argument and contend that instead a charge to tax arises under the accrued income scheme – yes – appeal allowed
Citations:
[2006] UKSPC SPC00549, [2006] STC (SCD) 543
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 24 August 2022; Ref: scu.242831