Trustees of Morrison 2002 Maintenance Trust and others v Revenue and Customs Commissioners

Capital gains tax – Tax avoidance scheme. The First-Tier Tribunal (Tax Chamber)(the FTT) had not erred in deciding that the transaction entered into by the trustees of a family trust and the settlor of those trusts, involving the disposal of certain shares effected by means of a tax avoidance scheme, had amounted to a single composite transaction in which the trustees had disposed of the shares at or about market value on which substantial capital gains tax (CGT) was chargeable. The Upper Tribunal (Tax Chamber) so held in dismissing the appellants' appeal against the FTT's decision to uphold closure notices issued by the Revenue and Customs Commissioners amending the taxpayers' self-assessment returns so as to increase the chargeable gains accruing for CGT.

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