Hancock and another v Revenue and Customs Commissioners

Capital gains tax – Disposal of assets. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by the Revenue and Customs Commissioners against a decision of the First-tier Tribunal (Tax Chamber) to the effect that a disposal of cash by the taxpayers of two loan notes did not bring into charge an accrued capital gain. The tribunal decided that the effect of the conversion of those loan notes fell to be treated as one conversion to which s 116(1) of the Taxation of Chargeable Gains Act 1992 applied so that on the conversion of the successor notes, the frozen gain was realised under s 116(10) of that Act.

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