Philip Savva and Others v The Commissioners for HM Revenue and Customs: [2015] UKUT 0141 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Henderson and Judge Bishopp on 25 March 2015.
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.INCOME TAX — fixed rate notes stripped of interest coupons — whether difference between purchase price of stripped note and redemption value a “discount” within Schedule D Case III or ITTOIA s 369 — yes — whether notes “deeply discounted securities” — no — appeal dismissed.