Ramsay v HMRC [2013] UKUT 0226 (TCC)
Wills & Trusts Law Reports | December 2013 #135The 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...