Paul Hunt & Ors v The Commissioners for HMRC
| Judge | JOHN WOODMAN |
| Judgment Date | 12 May 2025 |
| Neutral Citation | [2025] UKFTT 538 (TC) |
| Year | 2025 |
| Court | First-tier Tribunal (Tax Chamber) |
| Counsel | Laurent Sykes Kc,Counsel,Imran Afzal,Riya Bhatt Of Counsel,For |
| Date | 12 May 2025 |
Neutral Citation: [2025] UKFTT 00538 (TC)
Case Number: TC09519
FIRST-TIER TRIBUNAL
TAX CHAMBER
Taylor House, London
Appeal reference: TC/2022/11170
TC/2022/11171
TC/2022/11173
INCOME TAX – transactions in securities (TIS) – does s.685(6) ITA 2007 contain a drafting
error capable of judicial correction – no – does s.685(6) apply to all returns of sums paid by
subscribers on the issue of securities – no –was the cancellation of shares relevant
consideration under s. 685(4) – yes – appeal dismissed
Heard on: 14 – 15 February 2025
Judgment date: 12 May 2025
Before
TRIBUNAL JUDGE MICHAELA SNELDERS
JOHN WOODMAN
Between
PAUL HUNT
JAMES HUNT
ROBERT DAVIS
Appellants
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant:Laurent Sykes KC of counsel, instructed by KPMG Ireland
For the Respondents: Imran Afzal and RiyaBhattofcounsel,instructed by the General
Counsel and Solicitor to HM Revenue and Customs
Get this document and AI-powered insights with a free trial of vLex and Vincent AI
Get Started for FreeStart Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting