CGT tax loss scheme was artificial (subscriber guide)
In Simon Padfield, Satnam Bhogal, Allan Dunn & Conor McCloskeyv HMRC [2020] TC07983, the First Tier Tribunal (FTT) held that a tax avoidance scheme involving derivative trading to generate an allowable loss and a tax-free gain in separate transactions had to be viewed as a whole, with the gain cancelling out the loss. This is an extended analysis of the case for subscribers.