Philip Savva and Others v The Commissioners for HM Revenue and Customs: [2015] UKUT 0141 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Henderson and Judge Bishopp on 25 March 2015.

Read the full decision in Philip Savva, Andrew Savva, Mario Savva, Savva Savva and Kalliopi Pericleous v The Commissioners for HM Revenue and Customs: [2015] UKUT 0141 (TCC).

INCOME TAX — fixed rate notes stripped of interest coupons — whether difference between purchase price of stripped note and redemption value a “discount” within Schedule D Case III or ITTOIA s 369 — yes — whether notes “deeply discounted securities” — no — appeal dismissed.

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