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Decision Number: |
TC 00498 |
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Appellant:
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Howard Peter Schofield |
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Respondent:
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The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
W Michael S TILDESLEY OBE
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Date Of Decision:
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30/04/2010 |
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Main Category:
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CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS |
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Main Subcategory:
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Other |
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Notes:
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CAPITAL GAINS TAX – ALLOWABLE LOSS – Tax scheme involving options – the Options entered into were interlinked – no separate commercial existence – part of an indivisible process – planned as a single continuous operation – disputed loss construed against the whole transaction involving the four Options – no allowable loss -– Appeal dismissed on substantive dispute
CAPITAL GAINS TAX – OPTIONS OVER GILTS – whether exempt under section 115 TCGA - Yes
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Decision(s) to Download:
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TC00498.doc 
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