26 July 2023

HMRC -v- JASPER ALEXANDER THIRLBY CONRAN

The UTT has released its decision in the case of HMRC -v- Jasper Alexander Thirlby Conran which concerns the valuation of transfer of a licensing agreement between group LLP to group company. The UTT decision confirms the orthodox view that where a shareholder sells a capital asset to his own company (or its subsidiary) at an overvalue, the excess is taxable on him as an income distribution.

Elizabeth Wilson KC and Sadiya Choudhury acted for HMRC.

To view a copy of the decision please click here