LLP was in business and tax transparent when members transferred loan notes to it
In GCH Corporation Ltd and others v HMRC [2024] UKFTT 922 (TC) (17 October) the FTT allowed the taxpayers’ appeals against capital taxes assessments relating to a transfer of loan notes to a limited liability partnership by its members.
Gregory Hutchings (GH) who worked in senior positions at Tomkins PLC (Tomkins) until 2000 was the trustee of three family trusts (‘the trusts’). The trusts and GCH Corporation Ltd (‘the company’) which GH controlled built up substantial shareholdings in Tomkins.
When a possible takeover of Tomkins was announced GH sought advice on the sale of the trusts’ and company’s shares and decided to incorporate GCH Active LLP (the LLP). The LLP’s activities were limited but it did purchase five unconnected shareholdings (two of which were disposed of shortly afterwards) financed...
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LLP was in business and tax transparent when members transferred loan notes to it
In GCH Corporation Ltd and others v HMRC [2024] UKFTT 922 (TC) (17 October) the FTT allowed the taxpayers’ appeals against capital taxes assessments relating to a transfer of loan notes to a limited liability partnership by its members.
Gregory Hutchings (GH) who worked in senior positions at Tomkins PLC (Tomkins) until 2000 was the trustee of three family trusts (‘the trusts’). The trusts and GCH Corporation Ltd (‘the company’) which GH controlled built up substantial shareholdings in Tomkins.
When a possible takeover of Tomkins was announced GH sought advice on the sale of the trusts’ and company’s shares and decided to incorporate GCH Active LLP (the LLP). The LLP’s activities were limited but it did purchase five unconnected shareholdings (two of which were disposed of shortly afterwards) financed...
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