HL Corporation tax – Chargeable gains – Allowable losses – Tax avoidance scheme involving disposal of shares by parent company following rights issue by subsidiary company – Consideration for rights issue – Whether market value or issue price – Finance Act 1965, s 22(4), Sch 7, para 4 – Whether loss to which scheme gave rise to be disregarded.
[1981] UKHL TC – 54 – 200, 1982 SLT 348, [1982] STC 30, 1982 SC (HL) 114, 54 TC 200, [1982] TR 535, [1980] TR 397
Bailii
Finance Act 1965 22(4)
Scotland
Cited by:
Cited – UBS Ag and Another v Revenue and Customs SC 9-Mar-2016
UBS AG devised an employee bonus scheme to take advantage of the provisions of Chapter 2 of the 2003 Act, with the sole purpose other than tax avoidance, and such consequential advantages as would flow from tax avoidance. Several pre-ordained steps . .
Lists of cited by and citing cases may be incomplete.
Corporation Tax
Updated: 10 January 2022; Ref: scu.559846
