The Commissioners for HM Revenue and Customs v (1) Anthony Hancock (2) Tracy Lee Hancock: [2016] UKUT 0081 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Rose and Judge Nowlan on 18 February 2016.

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

Read the full decision in The Commissioners for HM Revenue and Customs v Anthony Hancock and Tracy Lee Hancock: [2016] UKUT 0081 (TCC).

Capital gains tax – redemption of qualifying corporate bonds (QCBs) - scheme to avoid the application of s 116 TCGA to a conversion of non- QCBs into QCBs – s 116(1)(b) and s 132 - whether a single transaction of non- QCBs and QCBs into QCBs or two separate transactions – whether the conversion and redemption should be treated as a single composite transaction of the disposal/redemption of non-QCBs – the Ramsay principle.

Published 1 December 2016