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11 February 2019
A Kerrison v CRC, Upper Tribunal (Tax and Chancery Chamber), 22 January 2019
The taxpayer took part in a scheme known as Excalibur to generate capital losses. A new company Broadgate was incorporated in the Isle of Man and acquired a small UK retail trade. The taxpayer took out a loan and subscribed for shares in Broadgate. He then entered into two agreements with Braye an unconnected company. Under the first he sold his Broadgate shares to Braye. Under the second he granted Braye a put option to sell the shares back to him for their ‘fair value’ plus 9.1%. Braye exercised this option and the taxpayer took another loan to buy the shares. Broadgate established a subsidiary in the British Virgin Islands (BVI) Holdings which advanced an interest free loan to the taxpayer so he could repay the other two loans. The BVI loan was written off and the taxpayer donated his shares...
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