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Decision Number: TC 08391
Appellant: JASPER ALEXANDER THIRLBY CONRAN (1) JC VISION LTD (2)
Respondent: Her Majesty's Revenue & Customs
Chairmen / Special
Commissioners:
Date Of Decision: 03/02/2022
Main Category: PROCEDURE
Main Subcategory: Other
Notes: INCOME TAX AND CORPORATION TAX – disposal of a business to a group company – ascertaining market value – intangibles relief – whether payment was a distribution – substitution of market value under Schedule 29 FA 2002 - held – valuation of assets actually transferred was £1 – no chargeable gain realised on disposal – no distribution – market value required to be substituted for purposes of intangibles relief – appeal of first appellant allowed – appeal of second appellant dismissed
Decision(s) to Download: TC 08391.pdf TC 08391.pdf