Howard Peter Schofield v The Commissioners for HM Revenue and Customs: [2011] UKUT 306 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Warren and Judge Clark on 27 July 2011.

Read the full decision in Howard Peter Schofield v The Commissioners for HM Revenue and Customs: [2011] UKUT 306 (TCC).

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 by Tax Chamber on substantive dispute – Appeal dismissed

CAPITAL GAINS TAX – OPTIONS OVER GILTS – whether exempt under s 115 TCGA - No.

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