21 July 2014

FTT Decision: Hancock & Hancock v HMRC

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) – whether a single conversion of non-QCBs and QCBs into QCBs or two separate conversions – whether the conversion and redemption should be treated as a single composite transaction of the disposal/redemption of non-QCBs – the Ramsay principle

Richard Vallat acted for HMRC.

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