25 March 2015
UT Decision: Malcolm Healey v HMRC
INCOME TAX — floating rate notes stripped of intermediate interest coupons — whether difference between purchase price when coupons stripped and sale price when remaining coupons to redemption re-attached a capital or income gain — income — whether a “discount” within Schedule D Case III — yes — appeal dismissed
Kevin Prosser QC & Charles Bradley, instructed by Hotham Services Ltd, acted for the Appellant.
Click here for the full decision.
This content is provided free of charge for information purposes only. It does not constitute legal advice and should not be relied on as such. No responsibility for the accuracy and/or correctness of the information and commentary set out in the article, or for any consequences of relying on it, is assumed or accepted by any member of PCTC or by PCTC as a whole.
