DMWSHNZ Ltd (In Members' Voluntary Liquidation) v The Commissioners for HM Revenue and Customs: [2014] UKUT 0098 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Rose on 3 March 2014.
Read the full decision in .
Corporation tax 鈥� disposal of qualifying corporate bonds 鈥� disposal of debts - section 116(10) Taxation of Chargeable Gains Act 1992 鈥� held-over capital gain brought into charge 鈥� joint election under section 171A TCGA 鈥� whether disposal by repayment of the debt underlying the bonds is a disposal 鈥榯o鈥� a person outside the corporate group 鈥� whether the bonds exist after the repayment of the debt and are disposed of 鈥榯o鈥� the debtor 鈥� reliance on extra-statutory material for construction of relevant provisions.
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Published 1 December 2016