‘Period of ownership’ determined by date of completion or date of exchange of contracts? (HMRC v Higgins)

Table of contents

• What are the practical implications of this case?
• What was the background?
• What did the UT decide?

Article summary

Private Client analysis: Christopher Stone, barrister at Devereux Chambers, acted successfully for HMRC in an Upper Tribunal (Tax and Chancery Chamber) (UT) ruling which took a purposive approach to interpreting the meaning of ‘period of ownership’ under the Taxation of Chargeable Gains Act 1992 (TCGA 1992).