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First-tier Tribunal (Tax)
You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> JASPER ALEXANDER THIRLBY CONRAN (1)JC VISION LTD (2) v Revenue & Customs (INCOME TAX AND CORPORATION TAX - disposal of a business to a group company) [2022] UKFTT 39 (TC) (03 February 2022)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08391.html
Cite as: [2022] UKFTT 39 (TC), [2022] STI 248
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| Decision Number: | TC 08391 |
| Appellant: | JASPER ALEXANDER THIRLBY CONRAN (1) JC VISION LTD (2) |
| Respondent: | Her Majesty's Revenue & Customs |
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Chairmen / Special Commissioners: |
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| Date Of Decision: | 03/02/2022 |
| Main Category: | PROCEDURE |
| Main Subcategory: | Other |
| Notes: | INCOME TAX AND CORPORATION TAX - disposal of a business to a group company - ascertaining market value - intangibles relief - whether payment was a distribution - substitution of market value under Schedule 29 FA 2002 - held - valuation of assets actually transferred was £1 - no chargeable gain realised on disposal - no distribution - market value required to be substituted for purposes of intangibles relief - appeal of first appellant allowed - appeal of second appellant dismissed |