The Commissioners for HM Revenue and Customs v (1) Anthony Hancock (2) Tracy Lee Hancock: [2016] UKUT 0081 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Rose and Judge Nowlan on 18 February 2016.
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.Capital gains tax – redemption of qualifying corporate bonds (QCBs) - scheme to avoid the application of s 116 TCGA to a conversion of non- QCBs into QCBs – s 116(1)(b) and s 132 - whether a single transaction of non- QCBs and QCBs into QCBs or two separate transactions – whether the conversion and redemption should be treated as a single composite transaction of the disposal/redemption of non-QCBs – the Ramsay principle.