Revenue and Customs v Michael and Elizabeth McQuillan (CAPITAL GAINS TAX) [2017] UKUT 344 (TCC) (6 September 2017)
CAPITAL GAINS TAX - entrepreneurs' relief - TCGA, Part V, Chapter 3 -
meaning of "personal company" - TCGA, s 169S(3) - application of
definition of "ordinary share capital" - ITA, s 989 - whether redeemable
shares with no right to a dividend were shares with a right to a dividend at a
fixed rate (of 0%) and thus not "ordinary share capital" - no - HMRC's
appeal allowed.
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