Nigel Grogan v The Commissioners for HM Revenue and Customs: [2010] UKUT 416 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Warren on 21 October 2010.
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Income tax – Transaction in securities – Contribution by Company to QUEST – Sale by controlling shareholder of shares to QUEST – Notice under ICTAs.703 to counteract tax advantage – Served after enactment of ITA 2007 – Alternative notice under ITA 2007, s.698 – Which notice effective – Whether tax advantage – Whether tax advantage a main object – Yes - Appeal dismissed.
Published 1 December 2016