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.