Garner (HMIT) v Pounds Shipowners & Shipbreakers Ltd and another
Garner (HMIT) v Pounds Shipowners & Shipbreakers Ltd and another
- 2000
- Estates Gazette [2000] 34 EG 84-87(4) .
HL 18 May 2000. Appellant taxpayers had each granted options to purchase land on identical terms. Appeals considered and decided on facts concerning the first company, P. Company secured the release of two restrictive covenants by paying £90,000. Revenue assessed the company to tax on the basis that the consideration for the disposal was £399,750. P contended that the £90,000 should be set off against the disposal consideration. CA rejected these contentions. Appellants appealed. Appeals dismissed.
RESTRICTIVE COVENANTS
GARNER (HMIT) V POUNDS SHIPOWNERS & SHIPBREAKERS LTD AND ANOTHER
CAPITAL GAINS TAX
OPTION PRICE
HL 18 May 2000. Appellant taxpayers had each granted options to purchase land on identical terms. Appeals considered and decided on facts concerning the first company, P. Company secured the release of two restrictive covenants by paying £90,000. Revenue assessed the company to tax on the basis that the consideration for the disposal was £399,750. P contended that the £90,000 should be set off against the disposal consideration. CA rejected these contentions. Appellants appealed. Appeals dismissed.
RESTRICTIVE COVENANTS
GARNER (HMIT) V POUNDS SHIPOWNERS & SHIPBREAKERS LTD AND ANOTHER
CAPITAL GAINS TAX
OPTION PRICE