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The taxpayer’s arguments finally got the axe in the long-running saga of Gray’s Timber Products Limited. DAVID BOWES considers the implications of the Supreme Court decision
KEY POINTS
- A reminder of the facts of the case.
- The market value rule for the purposes of TCGA 1992 s 272 and ITEPA 2003 Part 7.
- The decisions of the Special Commissioner and the judges in the Court of Session and the Supreme Court.
- The taxpayer’s rights were not contained in the articles of association.
- Did the subscription agreement create new rights?
- Is it time to clarify ITEPA 2003 Part 7?
I suspect that I was not alone in awaiting with some interest the Supreme Court decision in the case of Gray’s Timber Products v CRC [2010] UKSC 4 which was heard in December 2009.
My understanding was that the outcome could be expected within twelve weeks but if that was so the...
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