HMRC succeeded in front of the Upper Tribunal in its appeal against a First-tier Tribunal decision about the tax planning undertaken by Mr and Mrs Hancock. The Hancocks had sold their trading company in return for loan notes which constituted a mixture of qualifying corporate bonds (QCBs) and non-qualifying corporate bonds (non-QCBs). Tax planning was subsequently undertaken with a view to the eventual redemption of the loan notes being free of CGT. Mr and Mrs Hancock succeeded on the technical issues in front of the FTT but the UT took the opposite view. Neither tribunal accepted HMRC’s views of the Ramsay doctrine.
