Appeal regarding application of the four-year statutory limitation period, s865 TCA 1997
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Appeal against two alternative assessments made in relation to the same transaction. The assessment to capital gains tax relates to the denial of retirement relief on a sale of shares and a refusal to treat a share-for-share exchange as a reorganisation of share capital on the basis that the transactions were not made for bona fide commercial reasons and the main purpose or one of the main purposes of the transactions was to avoid a liability to tax. The assessment to income tax relates to the refusal to allow a sale of shares in a close company to be treated as a capital transaction on the basis that it was not a bona fide commercial transaction and was part of a scheme or arrangement the purpose or one of the purposes was the avoidance of tax, s584 TCA 1997; s586 TCA 1997; s598 TCA 1997; s817 TCA 1997
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Appeal regarding income tax assessment and entitlement to private residence relief
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Appeal regarding repayment of tax in the context of the four-year statutory limitation period
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