Howard Peter Schofield v The Commissioners for HM Revenue and Customs: [2011] UKUT 306 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Warren and Judge Clark on 27 July 2011.
Read the full decision in .
CAPITAL GAINS TAX 鈥� ALLOWABLE LOSS 鈥� Tax scheme involving options 鈥� the Options entered into were interlinked 鈥� no separate commercial existence 鈥� part of an indivisible process 鈥� planned as a single continuous operation 鈥� disputed loss construed against the whole transaction involving the four Options 鈥� no allowable loss -鈥� Appeal dismissed by Tax Chamber on substantive dispute 鈥� Appeal dismissed
CAPITAL GAINS TAX 鈥� OPTIONS OVER GILTS 鈥� whether exempt under s 115 TCGA - No.
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Published 1 December 2016