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Tax Titbits - June 2019

Stephen Yates, Rawlinson & Hunter, 01/07/2019

QCB and non-QCB consideration for sale of shares

The Supreme Court decision in Hancock and another v CRC UKSC 24 ruled against a scheme which attempted to avoid CGT on conversion of a mixture of QCBs and non-QCBs, received following the sale of a company, into a single holding of QCBs. There was an unintended loophole in section 116 TCGA 1992, and the court accepted that the words of that section provided powerful arguments for the taxpayers, but Lady Arden ruled that the clear intention of Parliament should prevail. The capital gain was frozen on the conversion, to be char...


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