[2011] UKUT 81 (TCC).

Upper Tribunal (Tax and Chancery Chamber).

Lewison J.

Decision released 25 February 2011.

Income tax – Tax avoidance – Gilt strips – Discounts – Loss from discount – Computation of loss – Scheme designed to create excess of amount paid for strip over the amount payable on transfer – Excess represented by premium for grant by taxpayer of call option – Whether option price to be added back in determining amount payable on the taxpayer’s transfer – Application of Ramsay principle – Taxpayer’s appeal dismissed – FA 1996, Sch. 13, para. 14A.

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