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G A Eccles v HMRC

In G A Eccles v HMRC [2019] UKFTT 95 (12 February 2019) the FTT found that no relief was available under TCGA 1992 s 253 in relation to a payment under a guarantee.

MCE was set up as a joint venture with the aim of purchasing and developing a site. It obtained planning permission but was ‘unable to continue with the planned development due to the slump in property prices’. Mr Eccles had made a payment to the company’s bank but his claim for relief under TCGA 1992 s 253 had been disallowed by HMRC.

HMRC’s view was that the capital loss did not arise until the payment was made on 26 March 2012 and which falling in 2011/12 could not be used to offset any capital gain liability for earlier years.

The FTT accepted that Mr Eccles had made the payment under the guarantee of a bank...

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