Valid claim

Application for negligible value claim

The taxpayer made a negligible value claim (TCGA 1992 s 24(2)) in his 2010-11 self assessment. HMRC disallowed it on the basis that he had not declared it correctly within the permitted time.

The claim related to losses on the disposal of shares in TEL on its liquidation in 2010. The taxpayer sold the shares on 12 May 2011. He emailed HMRC on the same day but before the disposal to lodge the claim. He did not refer specifically to a negligible value claim nor did he include the calculation or any evidence but he applied to postpone tax of the equivalent value. HMRC acknowledged that it received the communication but the taxpayer had not quantified the claim. Further he had submitted his 2010-11 tax return which included the loss claim in January 2012 but this was too late...