Bunting v HMRC: Taxpayer’s appeal against refusal of CGT loss relief claim allowed

In Timothy Bunting (TC9121) the First-tier Tribunal (FTT) allowed the taxpayer’s appeal confirming that capital gains tax (CGT) relief was allowable on an irrecoverable loan to a failing company despite the loan having been converted into worthless shares before the loss relief claim was made.

Background

The taxpayer Timothy Bunting had a successful career as a banker and subsequently as an investor. He also had a keen interest in sports history and memorabilia.

In July 2004 Mr Bunting established a trading company Rectory Sports Ltd (RSL) which sold sports books and memorabilia.

While Mr Bunting was not a shareholder or director of RSL himself (due to a preference by his then employer that he should not hold any external directorships) his wife was both a shareholder and director of RSL. Mr Bunting provided funding to RSL in the form of...