A and T Hancock v HMRC

Cathya Djanogly

Our pick of this week's cases:

In A and T Hancock v HMRC [2017] EWCA Civ 198 (25 May 2017) the Court of Appeal found that a scheme intended to operate as a reorganisation within the scope of TCGA 1992 ss 126 to 130 should be treated as two separate conversions so that the gain did not disappear ‘in a puff of smoke’.

Mr and Mrs Hancock had sold the entire share capital of their company Blubeckers Ltd to another company and the consideration had consisted in loan notes issued by the purchasing company. The loan notes provided for a repayment in US dollars at an exchange rate other than the one prevailing at the date of redemption. They were therefore not qualifying corporate...

If you are not a subscriber, subscribe now to read this content.

If you are already a subscriber, sign in

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.

Once you have registered, you will receive an email directing you back to read this article in full.