The Commissioners for HM Revenue and Customs v Michael and Elizabeth McQuillan: [2017] UKUT 0344 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Rose and Judge Berner on 6 September 2017.
Read the full decision in .
CAPITAL GAINS TAX 鈥� entrepreneurs鈥� relief 鈥� TCGA, Part V, Chapter 3 鈥� meaning of 鈥減ersonal company鈥� 鈥� TCGA, s 169S(3) - application of definition of 鈥渙rdinary share capital鈥� 鈥� ITA, s 989 鈥� 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 鈥渙rdinary share capital鈥� 鈥� no 鈥� HMRC鈥檚 appeal allowed.
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Published 6 September 2017