Income tax relief for gifts of shares to charity

13 May 2014

A tribunal appeal case has been published regarding the relief claimed on a high number of Gifted Shares.

The case is an appeal by Mr Nicholas Green against a Closure 5 Notice dated 27 June 2011 under section 28A Taxes Management Act 1970 amending his self assessment return for the year 2007/08.

The amendment disallowed in part his claim for relief in respect of two gifts of 118,750 shares of 0.1p each in Chartersea Limited to each of the National Eczema Society and the Alzheimer’s Society on 4 April 2008.

Mr Green had claimed relief under section 431 of the Income Tax Act 2007 of £237,500 based on a market value of £1.00 per Gifted Share. The Respondents’ officer did not accept that this amount reflected the market value of the Gifted Shares at that date.She considered that their market value was only 30p per Gifted Share. She restricted Mr Green’s claim for relief to £71,250 (a disallowance of £166,250) and amended his return on that basis.

The full details of the case can be accessed through the link below.

Income Tax Tribunal - N Green v HMRC - April 2014

Read HMRC’s press release