P Hunt and others v HMRC

In P Hunt and others v HMRC [2024] UKFTT 78 (TC) (22 January 2024) the FTT allowed HMRC’s stay application pending the determination of another appeal as the question of whether consideration paid by a company comprised 'relevant consideration' was central to both appeals.

The taxpayers were appealing against assessments raised under the transactions in securities regime. HMRC applied for their appeals to be stayed behind another group of cases which although they are not on precisely the same facts do involve the consideration of the same key point whether what was received by the taxpayer was ‘relevant consideration’ within the meaning of ITA 2007 s 685(4) and whether the provisions of s 685(6) applied and thus within the charge to income tax.

The taxpayers objected to HMRC’s application for a stay. They raised a number of grounds including...