In the case of HMRC v Sir Alexander Fraser Morrison, the Upper Tribunal found that a payment made in settlement of a High Court action was not a contingent liability under TCGA 1992 s 49, thus overturning the decision of the First-tier Tribunal. Paul Howard examines what this would mean in similar situations.
Howard Murray and Sara Stewart take a look at the main tax issues as well as any other particular issues arising from pre-sale hive-downs and debt reorganisations.
Malcolm Finney answers a query on split-year residence and the sale of shares.