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HMRC v J Blackwell

In HMRC v J Blackwell [2015] UKUT 418 (13 August 2015) the UT found that a payment made by a shareholder to enable him to sell his shares was not deductible from his taxable gain.

Mr Blackwell had held shares in BP Holdings which enabled him to veto a special resolution including one to approve a takeover. Following an unsuccessful takeover attempt by Taylor & Francis Group the group had entered into an agreement with Mr Blackwell to do and not to do certain things connected with his shares in return for £1m. Wishing to later accept a much higher offer from another bidder Mr Blackwell had then paid Taylor & Francis £25m under a second agreement in order to be released from his obligations towards the group. The issue was whether this payment could be deducted from the gain made by Mr Blackwell on...

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