WAYNE BOTTOMERBEVERLEY BOTTOMER v Revenue & Customs (Capital gains tax - deductibility of costs in computing gain - disposal of residential property)

Capital gains tax - deductibility of costs in computing gain - disposal of residential property - profit share paid for introduction of opportunity and assistance with management of project - whether deductible as incidental cost of acquisition or disposal - s.38 TCGA 1992

For the Respondents: �� Ellis Davies, litigator of HM Revenue and Customs� Solicitor�s Office

             Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings. As such, the hearing was held in public.

             These appeals chiefly concern the deductibility, for capital gains tax purposes, of certain sums paid by the Appellants in relation to the purchase, renovation and later disposal of a residential property in Walsall.

             The sums in question, totalling �31,906.50 (representing one half of the gain made on the disposal, after deducting the renovation costs), were paid by the Appellants to an unconnected third party who had initially introduced them to the opportunity and had subsequently performed some oversight functions in relation to the renovation.