M GROUP HOLDINGS LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2023] UKUT 00213 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Michael Green and Upper Tribunal Judge Phyliss Ramshaw on 31 August 2023
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Corporation Tax – Gain on disposal of shareholding – Substantial Shareholding Exemption – interpretation of paragraphs 15A and 26 of Schedule 7AC Taxation of Chargeable Gains Act 1992 – whether 15A applies to a period when a company was not part of a group – no. Meaning of “Group” – must be more than one company.
Published 31 August 2023