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Howard Schofield v HMRC; UTTC 27 Jul 2011

References: [2011] UKUT 306 (TCC), [2011] BTC 1800, [2011] STI 2775, [2011] STC 1920
Links: Bailii
Coram: Warren J P
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

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