»Ê¹ÚÌåÓýapp

54TC101

»Ê¹ÚÌåÓýapp Ramsay case involved a company which had incurred an agreed gain on the sale of a farm. It then entered into an avoidance scheme designed to produce an allowable loss to set off against the gain. »Ê¹ÚÌåÓýapp scheme removed value from a chargeable asset (shares) to produce an allowable loss on their disposal. »Ê¹ÚÌåÓýapp value passed into a loan, known as L2. This loan was also disposed of. If L2 was not a debt on a security, it would not be a chargeable asset. »Ê¹ÚÌåÓýapprefore the gain on the disposal of the loan would not have been chargeable. However, the House of Lords held that the loan L2 did amount to a debt on a security. »Ê¹ÚÌåÓýapp gain on the disposal of L2 was thus a chargeable gain and the scheme failed.