J Netley v HMRC

Cathya Djanogly

In J Netley v HMRC [2017] UKFTT 442 (26 May 2017) the FTT partially allowed the appeal which turned on the valuation of shares for the purpose of a gift to charity (ICTA 1988 s 587B).

This was a lead case and the issue was the market value of the shares in Frenkel Topping Group (FTG) which Mr Netley had disposed of by way of gift to charity.

FTG was quoted on the Alternative Investment Market (AIM) on 28 July 2004. At that time Mr Netley was one of a number of shareholders who held shares in the company. On the same date he gifted shares to St Ann’s Hospice a charity. He claimed that the value of his shares on that date was 48p evidenced by the price at which shares were traded on AIM.

The amount of tax relief generated by Mr...

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