Morrison 2002 Maintenance Trust, The Trustees of and Others v Revenue and Customs (Capital Gains Tax/Taxation of Chargeable Gains : Disposal): FTTTx 13 Apr 2016

FTTTx CAPITAL GAINS TAX – Tax avoidance scheme; trusts; sale of shares; put option; effect of contingencies, whether sale of trust assets to Irish trust under option agreement, subsequent sale for market value and ‘repatriation’ of the trust to Scotland avoids liability to capital gains tax; or whether there is a single composite transaction on which Capital Gains Tax on market value is chargeable; Taxation of Chargeable Gains Act 1992 ss2, 17, 18, 86, 144, 144ZA; appeals dismissed.

[2016] UKFTT 250 (TC)
Bailii
England and Wales

Capital Gains Tax

Updated: 14 January 2022; Ref: scu.562868