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Land Securities PLC v HMRC

In Land Securities PLC v HMRC (Upper Tribunal – 14 March) a company (L) entered into a series of transactions between March and September 2003 disposing of nine shares which it had acquired in 1969 and reacquiring them six months later. The transactions were intended to exploit a perceived loophole in TCGA 1992 s 106 (which has subsequently been repealed) and create a capital loss for tax purposes of £200 000 000. HMRC rejected the claims on the basis that the value-shifting provisions of TCGA 1992 s 30 applied to diminish the loss. The Upper Tribunal dismissed L’s appeal. Roth J held that for the purpose of s 30(9) the ‘relevant acquisition of the asset’ was the reacquisition of the shares in September 2003 rather than their original acquisition in 1969 so that this was ‘a case in which the...

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