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.

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
1 December 2016
Category:
Tax
Release date:
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.

Published 1 December 2016