Roger and Jean Dyer v HMRC

In Roger and Jean Dyer v HMRC (TC03073 – 22November 2013) the taxpayers had purchased shares in a company owned by their daughter Miss Dyer a renown fashion designer. The shares had been issued by way of debt capitalization. The company had since then been wound up and the taxpayers had claimed relief under TCGA 1992 s 24(2) on the basis that their shares had become of ‘negligible value’. HMRC had denied the claim on the ground that the shares had not become of negligible value they had been of negligible value from the time of their acquisition by the taxpayers.

It was accepted that Miss Dyer had established a solid reputation in the fashion world and that therefore the various intellectual property rights attached to her brand were very valuable. However she had never entered into a formal employment contract with the company in which...