Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest
tax developments that matter affecting private clients.
Blackwell: payment for release from exclusivity agreement not deductible
In Blackwell v HMRC [2017] EWCA Civ 232 (reported at page 4)Mr Blackwell had owned shares in a family business and his vote was necessary to secure inter alia any special resolutions of the company. He entered into a confidential agreement with a potential buyer (A) of the company in return for £1m which bound him to vote his shares in favour of A.
Sometime later Mr Blackwell was informed that a US firm (B) was prepared to make a much higher offer than A. Mr Blackwell could not agree the takeover by B without breaching his agreement with A. After negotiation he paid £17.5m to A to extinguish its rights under their...
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Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest
tax developments that matter affecting private clients.
Blackwell: payment for release from exclusivity agreement not deductible
In Blackwell v HMRC [2017] EWCA Civ 232 (reported at page 4)Mr Blackwell had owned shares in a family business and his vote was necessary to secure inter alia any special resolutions of the company. He entered into a confidential agreement with a potential buyer (A) of the company in return for £1m which bound him to vote his shares in favour of A.
Sometime later Mr Blackwell was informed that a US firm (B) was prepared to make a much higher offer than A. Mr Blackwell could not agree the takeover by B without breaching his agreement with A. After negotiation he paid £17.5m to A to extinguish its rights under their...
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:
