HMRC v Parry & ors [2018] WTLR 1267

Winter 2018 #170

Mrs Staveley established a company known as Morayford with her husband Mr Staveley. She was director of the company, and had a large pension fund with its occupational pension scheme. She divorced from her husband in 2000. Indeed the terms of the divorce, her share of the pension scheme was to be transferred to her. In July 2000, and upon advice, she transferred her fund from the Morayford scheme to a s32 scheme.

In 2004, she was diagnosed in December 2004 with cancer. In 2006, by which time her prognosis was poor, she was advised to transfer her pension fund into a perso...

Ramsay v HMRC [2013] UKUT 0226 (TCC)

December 2013 #135

The appellant appealed against a decision of the First-tier Tribunal (FTT). The issue before the FTT was whether Mrs Ramsay had transferred to TPQ Developments Ltd (TPQ) a ‘business as a going concern’ in exchange for shares issued by TPQ so as to qualify for roll-over relief under s162 Taxation of Chargeable Gains Act 1992 (TCGA 1992). The FTT found that what Mrs Ramsay had transferred to TPQ was not a business within the meaning of s162 of the TCGA 1992.

Mr and Mrs Ramsay owned a property known as Moat House in Belfast (the property). On 1...