Discovery assessments on the acquisition and disposal of a property in Switzerland for consideration in Swiss Francs were calculated on the correct basis.
The appellants acquired a property in Switzerland in August 1988. The consideration for the property (and costs of acquisition) was in Swiss Francs. The appellants sold the property in January 2010, also for consideration in Swiss Francs.
The appellants’ tax returns made no mention of a gain on disposal of the property. HM Revenue and Customs (HMRC) subsequently issued discovery assessments for 2009/10. The appellants disputed the amounts of the assessments.
The appellants argued that the correct way to calculate the chargeable gain on disposal was firstly to calculate the gain in Swiss Francs by subtracting the aggregate of the expenditure incurred in respect of the property (in Swiss Francs) from the Swiss Franc disposal proceeds. That
