DMWSHNZ Ltd (In Members' Voluntary Liquidation) v The Commissioners for HM Revenue and Customs: [2014] UKUT 0098 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Rose on 3 March 2014.

Read the full decision in DMWSHNZ Ltd (In Members’ Voluntary Liquidation) v The Commissioners for HM Revenue and Customs.

Corporation tax – disposal of qualifying corporate bonds – disposal of debts - section 116(10) Taxation of Chargeable Gains Act 1992 – held-over capital gain brought into charge – joint election under section 171A TCGA – whether disposal by repayment of the debt underlying the bonds is a disposal ‘to’ a person outside the corporate group – whether the bonds exist after the repayment of the debt and are disposed of ‘to’ the debtor – reliance on extra-statutory material for construction of relevant provisions.

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