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09 May 2014

FTT Decision: Ferguson v HMRC

Income tax – tax avoidance scheme involving “gifts to charity” relief – s 587B ICTA – preexisting option arrangements, secured by charges, for securities in question to be acquired from charity for 1% of value following charity’s receipt of them – whether Appellant had disposed of whole of the beneficial interest in the securities to the charity – held no – effect of composite transaction was that the disposal was, as to 99% of the value, to the Appellant’s own family trust – additionally, any disposal to the charity was “by way of a bargain made at arm’s length” – s587B(1) therefore not satisfied – appeal dismissed

David Ewart QC & Charles Bradley, instructed by NT Advisors, acted for the Appellant.

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