The WLR Daily case summaries
[2010] WLR (D) 53
REVENUE — Capital gains tax — Group of companies — Taxpayer claiming to deduct capital loss against chargeable gains— Claim disallowed as loss between “connected persons” only deductible from chargeable gains arising on other disposals between same connected persons— Whether two companies “connected” because of connection between their ultimate holding companies — Whether “group” to be given ordinary meaning of “collection” — Whether “group” requiring common purpose— Income and Corporation Taxes Act 1988, s 416(2)— Taxation of Chargeable Gains Act 1992, ss 18, 28 and 286(5)(b)