Morrison v Revenue and Customs Commissioners

Capital gains tax – Computation of chargeable gains – Contingent liability. Court of Session: Allowing an appeal by a taxpayer against a decision of the Upper Tribunal, the court held that a sum a company chairman paid in settlement of a court action was made for a contingent liability in respect of representations he made on a disposal by way of sale of his shares in the company within the meaning of s 49(1)(c) of the Taxation of Chargeable Gains Act 1992, so as to require adjustment of his liability to capital gains tax under s 49(2).

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