HUGH EDWARD MARK OSMOND and MATTHEW CHARLES ALLEN v The Commissioners of His Majesty's Revenue and Customs [2025] UKUT 00183 (TCC)
Upper Tribunal Tax and Chancery decision of MR JUSTICE MEADE and JUDGE GUY BRANNAN on 13 June 2025
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INCOME TAX – transactions in securities - share buyback –– shares benefitting from EIS CGT disposal relief – main purpose to obtain CGT relief – was there necessarily a main purpose to obtain an income tax advantage