Judges:
Lord Justice Jonathan Parker Lord Justice Kennedy Lord Justice Longmore
Citations:
[2003] EWCA Civ 1792, [2004] STC 170, [2004] STI 51, [2004] BTC 3
Links:
Statutes:
Taxation of Chargeable Gains Act 1992 77(2)
Jurisdiction:
England and Wales
Citing:
Appeal from – West and Others (HM Inspector of Taxes) v Trennery and others ChD 1-Apr-2003
The taxpayers had adopted the ‘flip-flop’ scheme to reduce their Capital Gains Tax liability.
Held: The section was intended to prevent relief where the settlor retained some direct or indirect benefit. Derived property was defined to include . .
Cited by:
Appeal from – Trennery v West (Inspector of Taxes) HL 27-Jan-2005
The House considered the application of the section to ‘flip-flop trusts’. The section allocated liability to charge on gains within a settlement under certain circumstances onto the settlor, and at his rate of tax. Assets were allocated to two . .
Lists of cited by and citing cases may be incomplete.
Capital Gains Tax
Updated: 08 June 2022; Ref: scu.189923
