Market leading insight for tax experts
View online issue

Cases: Summer 2019 review

1. Hancock: CGT scheme failed

In Hancock and another v HMRC [2019] UKSC 24 (22 May 2019) the Supreme Court like 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. 

Mr and Mrs Hancock had sold the entire share capital of their company to another company and the consideration had consisted of loan notes issued by the purchasing company. The loan notes were not qualifying corporate bonds (QCBs) for the purpose of TCGA 1992 s 117. The sale agreement provided for the payment of further consideration and the couple received further loan notes. These further notes constituted QCBs (following a variation). Both sets of loan notes were exchanged for two secured discounted loan notes which were QCBs and were eventually redeemed for cash.

The issue was...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

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.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.