Peter Vaines considers two recent cases providing further insight on negligible value for capital gains purposes
The meaning of ‘negligible value’ for capital gains purpose was given a comprehensive examination in Barker Harper & Wickes v HMRC [2011] UKFTT 645 but two recent cases have added some further gloss on the subject. These are Dyer v HMRC (TC03073) and Robert Brown v HMRC (TC03118).
In each case the taxpayer claimed that shares in a company in which they had invested had become of negligible value. In each case the tribunal considered whether the shares were worth ‘next to nothing’ (although not necessarily nil) or whether the shares had a market value. If they had a market value they are not of negligible value even if that value is negligible compared with the taxpayer’s acquisition value.
In Dyer there was no dispute that the shares...
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Home >Articles > Further gloss on negligible value
Further gloss on negligible value
Peter Vaines considers two recent cases providing further insight on negligible value for capital gains purposes
The meaning of ‘negligible value’ for capital gains purpose was given a comprehensive examination in Barker Harper & Wickes v HMRC [2011] UKFTT 645 but two recent cases have added some further gloss on the subject. These are Dyer v HMRC (TC03073) and Robert Brown v HMRC (TC03118).
In each case the taxpayer claimed that shares in a company in which they had invested had become of negligible value. In each case the tribunal considered whether the shares were worth ‘next to nothing’ (although not necessarily nil) or whether the shares had a market value. If they had a market value they are not of negligible value even if that value is negligible compared with the taxpayer’s acquisition value.
In Dyer there was no dispute that the shares...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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