Andrew Berry v The Commissioners for HM Revenue and Customs: [2011] UKUT 81 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Lewison on 25 February 2011.
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Key words: Tax avoidance – Income Tax – Discounts – Gilt strips – Computation of loss – Scheme designed to create excess of amount paid for the strip over the amount payable on transfer – Excess represented by “premium” for grant by taxpayer of call option – Whether option price to be added back in determining amount payable on the taxpayer’s transfer – Yes – Appeal dismissed – Para 14A Sch 13 FA 1996.
Published 1 December 2016