Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Linked transactions

21 June 2010
Issue: 4260 / Categories: Tax cases
Howard P Schofield (TC498)

The taxpayer sold his shares in PL Schofield Ltd for £11.84 million in the form of bank guaranteed loan notes. He redeemed the loan notes realising a chargeable gain of £10.726 million.

He reported a loss of more than £11 million in his 2002/03 tax return to offset the chargeable gain arising on the redemption of the loan notes. This loss had arisen as a result of his purchase of a put option in February 2003 which he disposed of on 4 April 2003.

The option arrangements were part of a purchased tax scheme designed to shelter the gains which the taxpayer had made on the loan notes.

The issue before the First-tier Tribunal was whether the surrender of the option on 4 April created an allowable loss.

The tribunal found from the evidence that the sole purpose of the...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon