CAPITAL GAINS TAX – Loss Relief for loans to traders – TCGA 1992 s 253 – Was a payment made by the Appellant towards a company’s indebtedness made ‘under a guarantee’ – Yes – Did the Appellant control the money which was the source of the payment? – Yes – When did the allowable loss arise? – When the payment was made under the personal guarantee, which was in March 2012 – Loss cannot be carried back to earlier years – Appeal dismissed
Citations:
[2019] UKFTT 95 (TC)
Links:
Jurisdiction:
England and Wales
Capital Gains Tax
Updated: 28 October 2022; Ref: scu.635694