In Spectros International plc v Madden 1997 STC 114 the purchasing company had agreed to discharge an overdraft. It was held that the amount of the overdraft should be included in the sales consideration.
Shares sold at undervalue did not mean that the bargain was otherwise than at arm's length. Bullivant Holdings v IRC 1998 STC 905
The taxpayer appealed Revenue's valuation of a shareholding and a discount factor applied the purposes of ascertaining the base cost of shares. The burden of proof rested with the taxpayers to show that the discount factor of 35 percent should not be applied to the shares acquired by them. The Tax Appeals Commissioner determined, having considered the expert reports, evidence, case law and legislation, that the taxpayer did not discharge the burden of proof. 12TACD2017
Whether the transfer of rights attaching to a class of shares to another class of shares was chargeable to income tax as a distribution 24TACD2018
This appeal considers whether the base cost of property for CGT purposes was the value at the date of grant of probate or the value on the date the Appellant became beneficially entitlement in possession to the property in question. The appeal also considered entitlement to Retirement Relief focusing on the meaning of a “chargeable business asset”. 156TACD2020