TIMOTHY WATTS v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00168 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Rupert Jones and Judge Ashley Greenbank on 12th June 2024
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TAX AVOIDANCE – INCOME TAX – loss determination on disposal of gilt strips – paragraph 14A Schedule 13 Finance Act 1996 – grant of option to trustee followed by assignment of option to a third party purchaser – payments made by purchaser to trustee for assignment of option to purchase and to taxpayer for exercise of the option - whether the FTT erred in including the amount paid by the purchaser to the trustee as a person other than the transferor as part of the ‘amount payable on the transfer’ under para 14A(3)(b) – appeal dismissed