Ramsay v HMRCC [2012] UKFTT 176 (TC)

Wills & Trusts Law Reports | March 2013 #127

In 2004, the appellant (Mrs Ramsay) and her husband transferred a property that they owned (Moat House) into a corporate vehicle, TPQ Developments Ltd, in exchange for shares in that company.

Moat House was a large property converted into ten flats. Five were occupied at the operative time.

On her tax return for 2004/05, Mrs Ramsay claimed relief under s162 Taxation of Chargeable Gains Act 1992 (TCGA) (rollover relief on the transfer to the company).

In September 2007 HMRC raised an enquiry notice.

Mrs Ramsay argued in correspondence that the nume...

Pawson (dec’d) v HMRCC [2012] UKFTT 51 (TC)

Wills & Trusts Law Reports | May 2012 #119

The appellants were the personal representatives of Nicolette Vivian Pawson (Mrs Pawson) and appealed against a notice of determination dated 1 October 2008. The notice had determined that Mrs Pawson’s 25% interest in a property known as Fairhaven, Thorpeness, Suffolk (Fairhaven) was subject to inheritance tax on a deemed disposal at the date of her death. The appellants contended that Fairhaven was entitled to relief as a relevant business property. Fairhaven was a large bungalow overlooking the sea in a holiday area. It had made a profit for each year since 2003, save for 2005/06...