.png)
.png)
06 October 2015
M Carey (TC4634)
The taxpayer had been living and working in the UK and was resident and ordinarily resident for several years before 2010/11. In January 2011 he took a sabbatical from his employment to work in Rwanda. In December 2011 his employment was terminated and he sold his employee shares to the employer.
In his 2010/11 return the taxpayer claimed split year treatment under extra statutory concession A11. In his 2011/12 return he claimed a capital loss of £145 827 on the sale of his shares against his employment income for that year (ITA 2007 s 131 and s 132). He also stated he was not resident and not ordinarily resident in that year.
HMRC refused the claim. The taxpayer appealed.
The First-tier Tribunal said the taxpayer had ceased to be...
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 'customer.services@lexisnexis.co.uk' for further assistance.
