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First-tier Tribunal (Tax) |
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You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> Adrian Kerrison v Revenue & Customs (CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS : Computation) [2017] UKFTT 322 (TC) (19 April 2017) URL: http://www.bailii.org/uk/cases/UKFTT/TC/2017/TC05800.html Cite as: [2017] UKFTT 322 (TC)(19 April 2017) |
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| Decision Number: | TC 05800 |
| Appellant: | Adrian Kerrison |
| Respondent: | The Commissioners for Her Majesty's Revenue & Customs |
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Chairmen / Special Commissioners: |
SARAH FALK |
| Date Of Decision: | 19/04/2017 |
| Main Category: | CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS |
| Main Subcategory: | Computation |
| Notes: | Income tax and capital gains tax – “bed and breakfast” scheme to generate capital loss under s 106A TCGA – claim to income tax relief for the loss under s 574 ICTA 1988 – whether “repo” rules in s 263A TCGA, value shifting rules in s 30 TCGA or Ramsay principles applied to prevent loss arising – whether waiver of loan to appellant gave rise to a receipt subject to income tax under s 687 ITTOIA 2005 (income not otherwise charged) – appeal allowed in part |
