Payment for release from exclusivity agreement was not expenditure deductible for CGT purposes (Upper Tribunal) | Practical Law

Payment for release from exclusivity agreement was not expenditure deductible for CGT purposes (Upper Tribunal) | Practical Law

The Upper Tribunal, allowing HMRC's appeal, has held that a shareholder's payment to effect his release from an exclusivity agreement was not tax deductible expenditure (base cost) falling within section 38(1) of the Taxation of Chargeable Gains Act 1992 (HMRC v Blackwell [2015] UKUT 0418 (TCC)).

Payment for release from exclusivity agreement was not expenditure deductible for CGT purposes (Upper Tribunal)

by Practical Law Tax
Published on 26 Aug 2015 • United Kingdom
The Upper Tribunal, allowing HMRC's appeal, has held that a shareholder's payment to effect his release from an exclusivity agreement was not tax deductible expenditure (base cost) falling within section 38(1) of the Taxation of Chargeable Gains Act 1992 (HMRC v Blackwell [2015] UKUT 0418 (TCC)).