In C Ferguson-Davie and another v HMRC [2024] UKFTT 321 (TC) (17 April 2024) the FTT dismissed the taxpayers’ appeal on carried interest. The FTT found that the carried interest ‘arose in connection with’ a disposal made after 8 July 2015 and so the transitionals provision did not apply.
The appellants appealed against assessments to CGT in respect of carried interest amounts arising in 2015/16 on the basis that the carried interest amounts in question fell within a transitional provision and accordingly were not subject to taxation under the rules for carried interest which applied from 8 July 2015.
The appeals were lead cases under Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Regulations SI 2009/2739 rule 18 behind which the appeals of 24 other individuals who were limited partners of the relevant limited partnership are stayed.
The appeals concerned whether the provisions of TCGA...
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In C Ferguson-Davie and another v HMRC [2024] UKFTT 321 (TC) (17 April 2024) the FTT dismissed the taxpayers’ appeal on carried interest. The FTT found that the carried interest ‘arose in connection with’ a disposal made after 8 July 2015 and so the transitionals provision did not apply.
The appellants appealed against assessments to CGT in respect of carried interest amounts arising in 2015/16 on the basis that the carried interest amounts in question fell within a transitional provision and accordingly were not subject to taxation under the rules for carried interest which applied from 8 July 2015.
The appeals were lead cases under Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Regulations SI 2009/2739 rule 18 behind which the appeals of 24 other individuals who were limited partners of the relevant limited partnership are stayed.
The appeals concerned whether the provisions of TCGA...
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