Andrew Berry v 皇冠体育app Commissioners for HM Revenue and Customs: [2011] UKUT 81 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Lewison on 25 February 2011.
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Key words: Tax avoidance 鈥� Income Tax 鈥� Discounts 鈥� Gilt strips 鈥� Computation of loss 鈥� Scheme designed to create excess of amount paid for the strip over the amount payable on transfer 鈥� Excess represented by 鈥減remium鈥� for grant by taxpayer of call option 鈥� Whether option price to be added back in determining amount payable on the taxpayer鈥檚 transfer 鈥� Yes 鈥� Appeal dismissed 鈥� Para 14A Sch 13 FA 1996.
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Published 1 December 2016