Adrian Kerrison and The Commissioners for HM Revenue and Customs:[2019] UKUT 0008 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Zacaroli and Judge Brannan on 22 January 2019.
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INCOME TAX AND CAPITAL GAINS TAX 鈥搒cheme to generate capital loss under s 106A TCGA 鈥� claim to income tax relief for the loss under s 574 ICTA 1988 鈥� whether 鈥渧alue shifting鈥� rules in s 30 TCGA applied to prevent a loss arising 鈥� whether waiver of loan to appellant gave rise to a receipt subject to income tax under s 687 ITTOIA 2005 (income not otherwise charged).
Updates to this page
Published 22 January 2019