M Pearson v HMRC

In M Pearson v HMRC [2017] UKFTT 780 (25 October 2017) the FTT found that a taxpayer who had been under an obligation to place the sale proceeds of a share disposal in an escrow account had a reasonable excuse for the late payment of CGT.

Mr Pearson had sold his company to a public company called Monitise and had received shares in Monitise as consideration. Under the sale agreement he was required to maintain an escrow account to provide security to Monitise for certain contingent liabilities. This account was to be funded by the sale of Monitise shares worth £13m. Mr Pearson sold half of the consideration shares for £6m and duly placed the proceeds into the blocked account. Shortly following completion the share price of Monitise started falling sharply. Mr Pearson did not sell his entire holding in the hope...