In R and J Dyer v HMRC [2016] UKUT 381 (2 September 2016) the UT found that a negligible value claim under TCGA 1992 s 24(2) must fail as the shares had been of no value at the time of their acquisition.
The taxpayers had purchased shares in a company JDDL owned by their daughter Miss Dyer a renowned fashion designer. The shares had been issued by way of debt capitalisation. The company had since then been wound up and the taxpayers had claimed relief on the basis that their shares had become of ‘negligible value’. HMRC had denied the claim on the ground that the shares had not become of negligible value; rather they had been of negligible value from the time of their acquisition by the taxpayers.
It was accepted that Miss Dyer had established a solid reputation in the fashion...
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