Ramsay v HMRCC [2012] UKFTT 176 (TC)

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...