The Upper Tax Tribunal has overturned the previous decision in the case of HMRC v Julian Blackwell, and decided that costs of £17.5m incurred to enable the taxpayer to sell his shares were not deductible for capital gains tax purposes.
The Facts
The taxpayer held shares in BP Holdings which entitled him to veto special resolutions, such as a takeover offer.
Following an unsuccessful takeover attempt, Taylor & Francis paid the taxpayer £1m in 2003 for his undertaking not use his veto against Taylor & Francis and not to incite a takeover offer from another firm.
Some years later, John Wiley & Sons made a substantial takeover offer, which the taxpayer wished to accept. However, he believed that 2003 agreement would prevent ...
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