Howard Schofield v HMRC: UTTC 27 Jul 2011

UTTC CAPITAL GAINS TAX – ALLOWABLE LOSS – Tax scheme involving options – the Options entered into were interlinked – no separate commercial existence – part of an indivisible process – planned as a single continuous operation – disputed loss construed against the whole transaction involving the four Options – no allowable loss – Appeal dismissed by Tax Chamber on substantive dispute – Appeal dismissed
CAPITAL GAINS TAX – OPTIONS OVER GILTS – whether exempt under s 115 TCGA

Warren J P
[2011] UKUT 306 (TCC), [2011] BTC 1800, [2011] STI 2775, [2011] STC 1920
Bailii
England and Wales

Capital Gains Tax

Updated: 01 November 2021; Ref: scu.448054