M GROUP HOLDINGS LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2023] UKUT 00213 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Michael Green and Upper Tribunal Judge Phyliss Ramshaw on 31 August 2023

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
31 August 2023
Category:
Tax
Release date:
31 August 2023

Read full decision in M Group holdings v HMRC final decision

Corporation Tax – Gain on disposal of shareholding – Substantial Shareholding Exemption – interpretation of paragraphs 15A and 26 of Schedule 7AC Taxation of Chargeable Gains Act 1992 – whether 15A applies to a period when a company was not part of a group – no. Meaning of “Group” – must be more than one company.

Updates to this page

Published 31 August 2023