The Commissioners for HMRC v Timothy Bunting
| Court | Upper Tribunal (Tax and Chancery Chamber) |
| Judge | Mrs Justice Joanna |
| Judgment Date | 19 March 2025 |
| Neutral Citation | [2025] UKUT 96 (TCC) |
| Date | 19 March 2025 |
| Year | 2025 |
| Counsel | Quinlan Windle,Counsel,Thomas Chacko,For |
Neutral Citation: [2025] UKUT 00096 (TCC)
Case Number: UT/2024/61
UPPER TRIBUNAL
(Tax and Chancery Chamber)
Rolls Building, London
CAPITAL GAINS TAX – entitlement to loss relief under s253 TCGA 1992 following
capitalisation of loan – appeal allowed
Heard on: 19 February 2025
Judgment date: 19 March 2025
Before
MRS JUSTICE JOANNA SMITH
JUDGE NICHOLAS ALEKSANDER
Between
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Appellants
and
TIMOTHY BUNTING
Respondent
Representation:
For the Appellants: Quinlan Windle, Counsel, instructed by the General Counsel and
Solicitor to His Majesty’s Revenue and Customs
For the Respondent: Thomas Chacko, Counsel, instructed by Evelyn Partners LLP,
chartered accountants
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