UT (Tax & Chancery) UT-2024-000113 - [2025] UKUT 00165 (TCC)

As persuasively as they were made, we reject Mr Grierson’s submissions and agree with those of Mr Carey. This ground does not give rise to any error of law on the part of the FTT.

We agree with the FTT’s reasoning and its conclusion at [61] that schedule 1B TMA applied to claims for share loss relief under s.574 ICTA so that the Appellant’s claim was to be treated as relating to 06-07 rather than 05-06. We find no error of law in the FTT’s conclusion that Derry SC only applied to s.132 ITA share loss relief claims and not in relation to s.574 ICTA share loss relief claims.

There were two parts to the FTT’s reasoning for its conclusion.

The first is that prior to the ITA, Schedule 1B TMA applied to share loss relief and other forms of loss relief – employment and trade loss relief - under ICTA.