The UT on Hancock: avoidance involving QCBs

Pete Miller

Pete Miller (The Miller Partnership) examines HMRC’s win in Hancock, where the Upper Tribunal decided that a redemption of loan notes had triggered a charge to CGT.

In HMRC v A and T L Hancock [2016] UKUT 81 (reported in Tax Journal 26 February 2016) the Upper Tribunal decided that the redemption of loan notes had triggered a charge to CGT.

The facts in the case

Mr and Mrs Hancock sold their trading company for consideration in the form of Loan notes to a total value of £9 279 000 plus an earn out. The initial consideration was split so that Mr Hancock received £500 000 A Loan Notes 2007 and £4 137 664 B Loan Notes 2004; and Mrs Hancock received £4 632 336 B Loan Notes 2004. The case only considers the B...

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Pete Miller (The Miller Partnership) examines HMRC’s win in Hancock, where the Upper Tribunal decided that a redemption of loan notes had triggered a charge to CGT.

In HMRC v A and T L Hancock [2016] UKUT 81 (reported in Tax Journal 26 February 2016) the Upper Tribunal decided that the redemption of loan notes had triggered a charge to CGT.