'just and reasonable' apportionment of sales proceeds

Acquisition cost, meaning under Taxation of Chargeable Gains Act 1992, s. 38

Acquisition of Capital Redemption Policies

Acquisition otherwise than by bargain at arm's length

Adjoining commercial land

Agreement to grant a lease, sham transaction

Allowable expenditure

Enhancement of value of property

Including deemed expenditure

Order of application of relief

Allowable loss

Annual exemption

Anti-avoidance provisions

Assets destroyed

Beneficiaries of non-resident settlements

Capital allowances, interaction




Computation of gain or loss on capital allowance assets

Connected persons

Corporation tax


Deferred unascertainable consideration

Depreciatory transactions, value shifting


Indexation allowance

Meaning of capital allowances and renewals allowances

Negligible assets


Oil and mining industries

Pre-entry losses

Rates of capital gains tax


Tangible movable property


Wasting assets qualifying for capital allowances

Allowable losses

Disposal of chargeable asset

Group of companies

Negligible value assets

Amended notice of assessment

Annual exemption


Appeal against assessment under Taxes Management Act 1970, s. 29 and related penalty

Appeal against disallowance of a holdover claim under TCGA 1992, s. 167

Appeal against HMRC's refusal to allow a capital loss

Appeal against penalties for the late filing of 2 NRCGT returns

Appeal against revenue assessment and penalty determination

Sale of residential property owned by appellant


– see Appeals

Appellant employed 'full-time abroad' in tax year 1999/2000, not treated as non-resident

Appellant entitled to Business Assets Taper Relief

Application for an extension of time, making of an appeal to the Tribunal

Application to admit oral witness evidence

Application to appeal out of time

Artificial scheme to create allowable loss


Agreement between taxpayer and Revenue


Application for permission to appeal out of time

Application for permission to make a late appeal

Discovery assessment

Further assessment and default interest

Incorrect year stated

Made out of time

Outside ordinary time limit


Sale of shares

Series of transactions

Asset purchased with, and sold for, Swiss Francs


– see Assets

Assets held on 6 April 1965

Election for valuation

Indexation allowance calculated before time apportionment

Land with development value

Avoidance scheme, sham documents

Bloodstock breeders

Building societies

Business asset taper relief

Land taken on 'conacre' arrangements

Northern Ireland

Occupied by appellant landowner wholly and mainly for purposes of husbandry

Property let to unlisted trading company

Sale of share of property

Trading company a 51% subsidiary of listed company

Capital contributions to Delaware company, enhancement expenditure

Capital distributions

Capital gains tax charge

Corporation tax



Non-residents dispose of UK residential property

Capital sum for release of option

Capital sums derived from assets


Cessation of trade

Change of intention

Charge on settlor with interest in settlement

Charge to tax

Capital gains tax

Companies exposure

Corporate trustees

Corporation tax

Determination of persons to be charged

European Economic Interest Groupings (EEIGs)

Gains and losses, computation



Insolvent individuals

Lenders enforcing their security

Lloyd's underwriters, trustees for

Nominees/bare trustees

Non-UK residential property interests, disposals


Personal representatives

Relevant high value disposal, computational rules

Residential property gain or loss


Trustees in bankruptcy

Trustees of settled property

Unit trust schemes, trustees


– see Charities

Chattel exemption

Choses in action

Claimed expenditure on capital improvements

Collection of tax


Composite transaction, Ramsay principle


Allowable expenditure

Base cost

Base date


Disposal proceeds

General principles

Income/capital, differentiation

Indexation allowance

Inflationary gains



Connected persons

Control over company

Family relationship


Group of persons, control by


Table of persons connected with individual/trustee or company

Trusts and settlements

Connected persons, capital loss on sale of shares


Debt forgiveness constituted non-cash consideration forming part of disposal proceeds

Disposal of shares, construction of share sale agreement

Disposal of shares, sum paid to appellant's church

Earn-out rights, validity of election

Hire purchase contract, exchange loss irrecoverable

Irrecoverable, depreciation of sterling

Meaning under Taxes Management Act 1970, s. 95

Options over land

Share sale

Shares included purchaser's obligation to pay debt

Surrender proceeds from second-hand life assurance policies

Wholly or exclusively for the acquisition of asset

Contingent liabilities, payment in settlement of High Court action

Contract settlement

Appellant seeking to challenge the contract

Jurisdiction of the tribunal

Corporation tax

Amount of gains charged to

Anti-avoidance provisions, use of capital losses

Appropriation of loss-bearing assets to stock-in trade

Assessment agreement not binding in subsequent years

Buying losses or gains, anti-avoidance provisions

Capital loss on sale of shares, value shifting

Capital losses

Consideration received under non-competition agreement, disposal of substantial shareholding

Construction costs of buildings/structures or works, interest paid on

Conversion of income into capital, anti-avoidance provisions

Disposal of options over land

Disposal of qualifying corporate bonds

Disposal of real estate

Disposal of securities

Disposal of substantial shareholding, consideration received under non-competition agreement

Double taxation relief

Exemption from degrouping charge, associated companies

Extent of

Foreign branch exemption regime

Forward currency contracts


Investment trusts

Joint election under TCGA 1992, s. 171A


Loss accruing after inter-group share exchange

Loss brought forward including loss on sale of subsidiary company

Mitigation scheme, derivative transactions


Payment in consideration for a covenant

Pre-entry gains and losses

Purchase by company of own shares

Receipt for abandonment of option

Receivership or administration

Recover of another person's tax

Relief for loans to traders

Repayment of debt underlying the bonds, disposal to the debtor

Replacement of business assets

Residence, disposal of business

Restructuring a company and its capital

Substantial shareholdings, exemption for disposals


Two per cent shareholdings, disposals and reacquisitions before 5 December 2005

Unincorporated association

Unit trust schemes

Unquoted shares in trading companies


Value shifting

Value shifting, elimination of capital loss on sale of shares


Costs previously included as revenue expenses in accounts

Cross options, single composite transaction

Deductibility of expenses

Deduction of gifted deposit

Deemed disposals

Absolute entitlement

Appointment of capital

Depreciatory transaction, indexation allowance

Determination of values under Taxation of Chargeable Gains Act 1992, s. 17, s. 272 and s. 273

Shareholdings of 51% and 9%

Different treatment of residents and non-residents

Discovery assessment

Discovery assessment denying relief

Discovery assessment, validity of

Discretionary trust, age of majority

Disposal of business by sole trader


Dissolution of partnership


Donatio mortis causa

Double taxation

Dual resident companies

Effect of claim for corresponding deficiency relief under Income Tax (Trading and Other Income) Act 2005

Enterprise investment scheme

Enterprise Investment Scheme deferral relief

Appellant existed wholly for purpose of carrying on a qualifying trade

CGT exemption only available if EIS relief claimed

Eligible shares

HMRC refusal to allow late claim for income tax relief

Income tax relief not claimed, income below personal allowance

Relationship with taper relief in relation to properties used for both business and non-business purposes

Entrepreneurs' relief

Disposal of syndicate capacity by Name at Lloyd's


Individual an officer or employee throughout the period of one year with date of disposal

Ordinary shares, meaning

Partial transfer of premises not the same as a part disposal

Penalty notice correctly issued as relief wrongly claimed

Personal company, meaning

Principles of statutory construction


Shares with no dividend rights have a right to a dividend at a fixed rate

Substituting agreed valuation for initial valuation

Transfer of audit clients a disposal of business assets

European company (SE)

Exchange of shares for loan notes

Exemptions from tax


Annual exempt amount


Assets of national, scientific, historic or artistic interest


Community amateur sports clubs

Decorations for valour or gallant conduct

Deposits and funds


Donatio mortis causa

European Bank for Reconstruction and Development (EBRD)

European School

Foreign currency


Government non-marketable securities

Housing associations

National heritage bodies

Passenger vehicles


Personal representatives

Principle private residence

Savings certificates


Seed enterprise investment scheme


Tangible movable property

Visiting forces

Winnings and damages

Exercise of share options, acquisition costs

Existing use value of constituent parts

Expenditure deductible in computing chargeable gain

Expenditure incurred on an asset

Expenditure reflected in the state or nature of the asset at the time of disposal

Experts adopting different valuation methodologies and concluding on different valuations

Extent of allowable deduction for expenditure allegedly incurred on provision or enhancement of goodwill disposed of

Extent of costs allowable in computation of gain on disposal of goodwill

Farming and market gardening

Flat bought by taxpayers originally owned by mother-in-law for principal private residence relief

Foreign assets

Bank deposits in foreign currency

Branch or agency, non-residents trading through


Foreign currency




– see Partnerships

Remittance basis


– see Residence

Situs of assets

Territorial scope of charge


Foreign currency, computation of gain or loss

Forfeited deposit on rescinded contract for purchase of land

Forfeited deposit on rescinded purchase contract

Formula in valuation office agency manual

Gains deferred (companies only from 6 April 2008)

Before 1982, 50 per cent relief

Between 1982 and 1988, 50 per cent relief

Gifts of shares in an unquoted company


Harbour authorities

History of taxation

Hold-over relief

Husband and wife

Husband and wife, disposals between

Incorporation relief under Taxation of Chargeable Gains Act 1992, s. 162

Indexation allowance


– see Information

Information notice, compliance

Inheritance tax interaction

Innaccuracy penalty

Insufficiency of capital gains tax, discovered

Interest on unpaid/overdue tax

Investment clubs


Land, basis of valuation

Late payment

Delay by HMRC

Reasonable excuse

Late payment penalty

Late return

Legatee, entitlement to deduction


Lloyd's underwriters


Loss relief, payment of debt under guarantee

Qualifying loan

Loss of capital gains tax attributable to negligent conduct of taxpayer

Lump sum payment for assignment of future rent, capital or income receipt

Marriage value

Mineral leases

Misstatements made of a disposal

Money used for payments on account

Mortgage fees deductible as incidental costs of disposal under TCGA 1992, s. 38(1)(c) and (2)

Negligence in making tax returns

Negligible value assets

Allowable losses

Company buyback scheme

Negligible value claim

Certificate of deposit denominated in sterling

Executors in respect of period before deceased's death


Non-resident companies

Non-resident company

Non-resident trusts


Oil companies


– see Options

Painting and decorating cost claimed as enhancement cost deductible under TCGA 1992, s. 38(1)(b)

Painting displayed in Castle Howard, wasting asset or plant

Parliamentary constituency associations


– see Partnerships

Payment of capital gains tax


Appellant negligent in submitting return including loss claimed as part of CGT loss generating scheme

Failure to file tax return

Failure to notify chargeability and inaccuracy


Late payment

Late return

Notice, breach of human rights

Special circumstances

Time to pay arrangement in force

Penalty for negligence under TMA 1970, s. 95

Pensions and similar benefits

Personal representatives

Preliminary issue

Principal private residence relief


Multiple properties

Not main residences

Penalties, deliberate or careless

Purchase of apartment off-plan

Residence, meaning

Taxpayer's residence

Private residence relief


Application to add a new ground of appeal in appellant's substantive appeal

Objection to evidence not supported by witness evidence

Proceeds of disposal

Property held as an adventure in nature of a trade or as a capital asset

Qualifying corporate bonds, disposal





Personal representatives



– see Re-basing

Recovery of tax

Redemption of qualifying corporate bonds

Refusal of HMRC to issue EIS 1

Reimbursement of development costs of property

Reliance on advice as to effectiveness of capital loss generation scheme

Reliance on advice from professional firms

Relief for loans to traders

Remittance of case back to special commissioners

Rent factoring scheme

Reorganisation or reduction of share capital

Repayment of tax paid under mistake of law/pursuant to unlawful demand

Replacement of business assets

Representation made of a disposal


– see Residence

Residence status

Residential property acquired with intention of own occupation

Retirement relief


– see Returns

Right to sue

Roll-over relief

Sale of residential property owned by appellant

Scheme to avoid the application of Taxation of Chargeable Gains Act 1992, s. 116

Scheme to defer tax

Seed enterprise investment scheme


– see also Bases of assessment

Penalty under Taxes Management Act 1970, s. 95(1)


– see also Settlements

Shares and securities

Short period of occupation sufficient to claim private residence relief

Statutory compensation

Superannuation payments

Tangible movable property

Taper relief

Taper relief, disposal of land

Relief for trading losses

Use of land for horse breeding

Taper relief, qualifying period

Tax avoidance

Application of Ramsay principle in series of transactions

Exchange of shares

Transfer of property for advantage of extra-statutory concession D2

Tax return claim that non-resident was 'negligent conduct'

Taxpayer in partnership with another



Conditional contracts

Disposal under contract

Option contract

Tonnage tax

– see Tonnage tax

Transfer of assets pursuant to consent order in divorce proceedings

Transfer of business to a company

Transfers at an undervalue to employees and directors


– see Settlements

UK-Mauritius double taxation convention


– see Valuation

Visiting forces

Wasting assets, extended lease