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TaxWednesday 21 December 2022

First-tier Tribunal Decision concerning the meaning of “the amount payable on the transfer” in relation to disposal of gilt strips

Watts v Commissioners for HM Revenue and Customs [2022] UKFTT 408 (TC)

Jonathan Davey KC has received judgment in a First-tier Tribunal (“FTT”) appeal regarding a pre-planned tax scheme involving the disposal of gilt strips. The issues raised in the appeal include the meaning of the phrase “the amount payable on the transfer” (paragraph 14A(3) of Schedule 13 to the Finance Act 1996). The FTT (Judge Heidi Poon) held that on a purposive construction of the relevant legislation, the phrase “the amount payable on the transfer” was to be interpreted more broadly than the Appellant contended for, and, accordingly, on the facts of the case, the “transfer” in question comprised the aggregate of two amounts including a payment made for the assignment of an option. The FTT therefore found for the Respondents on the point. Jonathan Davey KC acts for the Respondents (HMRC) with Joshua Carey (Deveraux Chambers); Aparna Nathan KC and Colm Kelly (Deveraux Chambers) act for the Appellant.

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