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) >> Dmwshnz Ltd v Revenue And Customs [2014] UKUT 98 (TCC) (3 March 2014)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2014/98.html
Cite as: [2014] STC 1440, [2014] UKUT 98 (TCC), [2014] BTC 509, [2014] STI 880

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Dmwshnz Ltd v Revenue And Customs [2014] UKUT 98 (TCC) (3 March 2014)

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

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