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03 March 2014

UT Decision: DMWSHNZ LTD v HMRC

Corporation tax – disposal of qualifying corporate bonds – disposal of debts – section 116(10) Taxation of Chargeable Gains Act 1992 – held-over capital gain brought into charge – joint election under section 171A TCGA – whether disposal by repayment of the debt underlying the bonds is a disposal ‘to’ a person outside the corporate group – whether the bonds exist after the repayment of the debt and are disposed of ‘to’ the debtor – reliance on extra-statutory material for construction of relevant provisions

Zizhen Yang, instructed by Ernst & Young LLP, acted for the Appellant.

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