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
|