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Jason Drummond v. The Commissioners for Her Majesty’s Revenue and Customs – Special Commissioners

CAPITAL GAINS TAX – Computation of gain – Second hand life assurance policy – Surrender proceeds brought into computation of chargeable event gain for income tax – Whether surrender proceeds to be excluded as disposal consideration for CGT purposes – No – TCGA 1992 s37(1)

CAPITAL GAINS TAX – Acquisition consideration – Wholly and exclusively for the acquisition of the asset – Second hand life assurance policies acquired for £210,000 above surrender value as part of tax avoidance scheme – Whether entire consideration incurred for acquisition of the policies or as part of pre-ordained tax avoidance scheme – Whether alternatively the £210,000 was consideration for acquisition of the policies – No – Appeal dismissed – TCGA s.38(1)

Patrick Way and Hui Ling McCarthy appeared for the Appellant

Timothy Brennan QC and Nicola Shaw appeared for the Respondent

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