Philip Savva and Others v The Commissioners for HM Revenue and Customs: [2015] UKUT 0141 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Henderson and Judge Bishopp on 25 March 2015.

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INCOME TAX 鈥 fixed rate notes stripped of interest coupons 鈥 whether difference between purchase price of stripped note and redemption value a 鈥渄iscount鈥 within Schedule D Case III or ITTOIA s 369 鈥 yes 鈥 whether notes 鈥渄eeply discounted securities鈥 鈥 no 鈥 appeal dismissed.

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Published 1 December 2016