18 February 2016
UT Decision: HMRC v Anthony Hancock & Tracy Lee Hancock
Capital gains tax-redemption of qualifying corporate bonds (QCBs)- scheme to avoid the application of s 116 TCGA to a conversion of non-QCBs into QCBs- s 116(1)(b) and s 132- whether a single transaction of non-QCBs and QCBs into QCBs or two separate transactions- whether the conversion and redemption should be treated as a single composite transaction of the disposal/redemption of non-QCBs- the Ramsay principle.
Elizabeth Wilson instructed by the General Counsel and Solicitor to HM Revenue & Customs, for the Respondents.
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