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Decision Number: TC 03525
Appellant: Mr Nicholas Green
Respondent: The Commissioners for Her Majesty's Revenue & Customs
Chairmen / Special
Commissioners:
Malcolm GAMMIE QC
Date Of Decision: 28/04/2014
Main Category: INCOME TAX/CORPORATION TAX
Main Subcategory: Exemptions and reliefs
Notes: INCOME TAX – Relief for gifts of shares to charity – whether arrangement
designed to enhance relief or create artificial tax losses – market value of shares on
initial listing – whether company’s main asset acquired shortly before listing at a
reduced price – if so, impact on value of listed shares – relevance of market
transactions on first day of listing – basis of valuation to be adopted –
determination of market value – appeal allowed and disallowance of relief on claim
re-determined
Decision(s) to Download: TC03525.pdf TC03525.pdf