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United Kingdom Upper Tribunal (Tax and Chancery Chamber) |
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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Mr Andrew Berry v HMRC v [2011] UKUT 81 (TCC) (25 February 2011) URL: http://www.bailii.org/uk/cases/UKUT/TCC/2011/81.html Cite as: [2011] UKUT 81 (TCC), [2011] STI 636, [2011] BTC 1623, [2011] STC 1057 |
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Tax avoidance – Income Tax – Discounts – Gilt strips – Computation of loss –Scheme designed to create excess of amount paid for the strip over the amount payable on transfer – Excess represented by "premium" for grant by taxpayer of call option – Whether option price to be added back in determining amount payable on the taxpayer’s transfer – Yes – Appeal dismissed – Para 14A Sch 13 FA 1996 See also: Costs
