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.

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.

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