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The High Court kicks the Revenue into touch in Wardhaugh v Penrith Rugby Union Football Club.
WHERE A GRANT was received in payment towards a new business asset this need not be deducted from the acquisition cost when computing entitlement to rollover relief.
Background
A new clubhouse was needed by Penrith Rugby Union Football Club. To help finance this it sold four acres of land which was surplus to requirements for £315 105. This resulted in a capital gain of £204 165 but the club claimed relief under section 152 Taxation of Chargeable Gains Act 1992 to 'roll over' this gain against the £600 459 cost of its new clubhouse.
Put simply section 152 allows the gain on the disposal of one business asset which would otherwise come into charge at that time to be deferred by deducting...
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