Tax: A successful flip-flop

Claire Randall and Katie Allard outline the tax implications of Bowring v HMRC, which concerned a scheme to reduce CGT on capital payments by a trust ‘The judgment in Bowring provides a useful insight for those involved in tax planning as to how the courts are likely to decide on similar issues in the future.’In …
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Bowring & anr v HMRC [2015] UKUT 550 (TCC)

Wills & Trusts Law Reports | January/February 2016 #156

The appellants (CB and JB) brought an appeal against a decision of the First-tier Tribunal (FTT) on 25 June 2013 in which it dismissed the appellants’ appeals against closure notices by HMRC containing amendments to the appellants’ self-assessment tax returns for 2002-03. The effect of the amendments was that the appellants were liable to capital gains tax (CGT) of £849,644 and £317,417 respectively of additional gains under s87 of the Taxation of Chargeable Gains Act 1992 (TCGA) and supplemental charges under TCGA, s91.

In 1969, the ap...