Market leading insight for tax experts
View online issue

J Shannon v HMRC

Taper relief and employment

In J Shannon v HMRC [2018] UKFTT 17 (9 January 2018) the FTT found that the vendor of shares in a company had not been employed by that company so that the shares did not constitute business assets for taper relief purposes.

Mr Shannon was director and shareholder of Supercuts. He had sold the majority of his shareholding to Regis a US company listed on the New York stock exchange for shares in Regis.

Mr Shannon had then sold some of his shares in Regis in the 2002/03 tax year and the balance in 2003/04. Under the taper relief rules (TCGA 1992 Sch A1) as they applied during the relevant years if the Regis shares were business assets the actual gain would be reduced by 75% after two years’ ownership giving an effective CGT rate of only 10% at a...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top