Edward Newfield v The Commissioners for HMRC

Edward Newfield v The Commissioners for HMRC

Section 66 of the Taxation of Chargeable Gains Act 1992 applies, deeming the property to have been held by the Appellant throughout the period, making him liable for capital gains tax on the entire gain; the Respondents are not estopped from assessing him as no clear promise or detrimental reliance was established.

Parties
Appellant: Edward Newfield; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
11 October 2024
Procedural Posture
Tax Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Capital Gains Tax, Beneficial Ownership, Bankruptcy, Promissory Estoppel

Case Brief

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Parties

Edward Newfield

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Final Judgment

  1. 1 Whether Section 66 of the Taxation of Chargeable Gains Act 1992 applies to deem the property to have been held by the Appellant throughout the period of bankruptcy
  2. 2 Whether the Respondents are estopped from assessing the Appellant to capital gains tax due to representations made during the dispute

Ratio Decidendi

Section 66 of the Taxation of Chargeable Gains Act 1992 applies, deeming the property to have been held by the Appellant throughout the period, making him liable for capital gains tax on the entire gain; the Respondents are not estopped from assessing him as no clear promise or detrimental reliance was established.

Court Disposition

Appeal dismissed

Orders

  • Assessment to capital gains tax upheld
  • Appellant liable for capital gains tax on chargeable gain