[2012] UKUT 362 (TCC).

Upper Tribunal (Tax and Chancery Chamber).

Newey J, Judge Greg Sinfield.

Decision released 19 October 2012.

Corporation tax – Scheme to avoid tax on chargeable gains – Whether derivative transactions gave rise to chargeable gains and losses – Whether loss arising on disposal of shares in group company allowable loss – Application of Ramsay principle – Income and Corporation Taxes Act 1988, s. 128 – Taxation of Chargeable Gains Act 1992, s. 2, 143.

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