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Drummond v Revenue and Customs: SCIT 5 Jul 2007

SCIT CAPITAL GAINS TAX – Computation of gain – Second hand life assurance policy – Surrender proceeds brought into computation of chargeable event gain for income tax – Whether surrender proceeds to be excluded as disposal consideration for CGT purposes – No – TCGA 1992 s37(1)
CAPITAL GAINS TAX – Acquisition consideration – Wholly and exclusively for the acquisition of the asset – Second hand life assurance policies acquired for andpound;210,000 above surrender value as part of tax avoidance scheme – Whether entire consideration incurred for acquisition of the policies or as part of pre-ordained tax avoidance scheme – Whether alternatively the andpound;210,000 was consideration for acquisition of the policies – No – Appeal dismissed – TCGA s.38(1)

Citations:

[2007] UKSPC SPC00617, [2007] STI 1818, [2007] STC (SCD) 682

Links:

Bailii

Jurisdiction:

England and Wales

Capital Gains Tax

Updated: 11 July 2022; Ref: scu.259271

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