Hardy v HMRC ~ Rory Mullan

Rory Mullan of Old Square Tax Chambers represented the taxpayer before the Upper Tribunal in Hardy v HMRC. The taxpayer appealed against HMRC’s refusal to allow capital losses in relation to forfeited deposits.

The Upper Tribunal held that contractual rights under a specifically enforceable contract are not assets for capital gains tax purposes with the result that the losses were not allowable.

A copy of the decision can be accessed here.

[Posted: 03 August 2016]