UT-2024-000019 - [2025] UKUT 00257 (TCC)

Of the £360,437 received from the sale of her shares, AP says that £36,048 was paid to HMRC as capital gains tax (with entrepreneur's relief). The shares gifted to her by her parents prior to the sale were gifted on the understanding that her parents would like any benefits received from those shares to be passed on to her children. Accordingly, she gifted approximately £78,460 (the net of tax proceeds of selling the shares her parents gave her) to her two children. The remaining £250,000 was invested in low interest savings. This enabled her to forgo a salary from Tressanda at a time when it was struggling.

In her third witness statement AP summarised her financial position in relation to her savings, pension and share of the matrimonial home. Before us, she updated the headline figures. Although we have not set them out in full here, we have borne these figures in mind when considering the CN figure.

AP earns a modest salary from working at an accountancy firm. She anticipates that she will lose this employment if a CN is issued against her due to the nature of her employment.