In the Scott case, HMRC’s refusal to allow special relief was held to be Wednesbury unreasonable. Blackwell denies deductibility of a payment for release from an exclusivity agreement against CGT. Ames highlights the requirement to claim EIS income tax relief before claiming CGT relief. The definition of ‘garden or grounds’ for primary residence relief from CGT is clarified in Fountain. Finally, the Guernsey Royal Court has decided that the Hastings Bass rule is available under Guernsey law.
