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.
To view a copy of the decision please click here