Market leading insight for tax experts
View online issue

HP Schofield v HMRC

In HP Schofield v HMRC (CA – 11 July) an individual (S) realised a substantial capital gain on the disposal of some loan notes in 2002/03. However in his tax return he claimed that he had made a loss of more than £11 000 000 on the disposal of a ‘put’ option. He had purchased the option on 7 February 2003 along with a corresponding ‘call’ option and disposed of it on 4 April 2003. (He disposed of the ‘call’ option on 7 April 2003 by which time he had become resident in Spain so that the gain on this disposal was outside the scope of UK CGT.) HMRC rejected the claim and S appealed. The First-tier Tribunal dismissed his appeal holding on the evidence that the options ‘were inextricably linked with each other to form a continuous process...

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.