United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Land Securities PLC v HM Revenue & Customs FTC/11/2012 [2013] UKUT 124 (TCC) (14 March 2013)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2013/124.html
Cite as: [2013] STI 1493, 81 TC 843, [2013] UKUT 124 (TCC), [2013] STC 1043, [2013] BTC 1773

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Land Securities PLC v HM Revenue & Customs FTC/11/2012 [2013] UKUT 124 (TCC) (14 March 2013)

"Corporation tax on capital gains – scheme to generate a capital loss in reliance on the identification rules for matching a disposal of shares with an acquisition under s 106 TCGA 1992 – value shifting rules in s 30 TCGA 1992 – application of s 30(9) notwithstanding that the shares were owned at the time of the disposal, where disposal and acquisition form part of the scheme which engages s 30 – whether, in the alternative, the disposal and acquisition for the purposes of s 30(9) is determined by the computational rules required by s 106 –Davies v Hicks applied – application of s 30(5) to eliminate the capital loss"

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