In Lloyd-Webber and another v HMRC [2019] UKFTT 717 (TC) the First-tier Tax Tribunal (FTT) found that the taxpayers’ payments made under contracts for land and properties to be built in Barbados gave rise to losses for CGT purposes even though the properties were never completed and the payments were made before the taxpayers disposed of their rights under those contracts.
In 2007 Lady and Lord Lloyd-Webber (the taxpayers) entered into contracts with the vendors to buy two plots of land in Barbados on which the vendors would build villas by 30 June 2009. A large deposit for each plot was paid and further payments were made in accordance with a schedule of payments at various stages of the process. By early 2009 due to the financial crisis construction of the villas had stopped.
In 2011 the taxpayers and the original vendors entered into further contracts under which...
