Tax

M Group Holdings Ltd v Revenue & Customs (substantial shareholding exemption)

[2021] UKFTT TC TC08054First-tier Tribunal (Tax)2021

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substantial shareholding exemption - schedule 7AC Taxation of Chargeable Gains Act 1992 - paragraphs 7 and 15A - whether relief available when the shares have been owned by a company in a group for less than 12 months - no

The hearing took place on 17 December 2020. With the consent of the parties, the form of the hearing was a video hearing, with all parties attending remotely, using the Tribunal video platform. A face to face hearing was not held because this was not considered appropriate during the coronavirus pandemic.

I was referred to electronic hearing bundles and skeleton arguments from both parties.

Richard Vallat QC, counsel, instructed by Gowling WLG (UK) LLP �for the Appellant

John Brinksmead-Stockham, counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents

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