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C Ferguson-Davie and another v HMRC

In C Ferguson-Davie and another v HMRC [2024] UKFTT 321 (TC) (17 April 2024)  the FTT dismissed the taxpayers’ appeal on carried interest. The FTT found that the carried interest ‘arose in connection with’ a disposal made after 8 July 2015 and so the transitionals provision did not apply. 

The appellants appealed against assessments to CGT in respect of carried interest amounts arising in 2015/16 on the basis that the carried interest amounts in question fell within a transitional provision and accordingly were not subject to taxation under the rules for carried interest which applied from 8 July 2015.   

The appeals were lead cases under Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Regulations SI 2009/2739 rule 18 behind which the appeals of 24 other individuals who were limited partners of the relevant limited partnership are stayed.   

The appeals concerned whether the provisions of TCGA 1992 s 103KA et seq. (the ‘carried...

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