Court of Appeal.

Judgments delivered 18 May 1983.

Capital gains tax – Deeds of allocation executed by settlement trustees – Whether deemed ‘disposal’ of assets took place – Finance Act 1965, sec. 25(3)Capital Gains Tax Act 1979, sec. 54(1).

  This was an appeal by the Crown from the decision of Nourse J., reported at 82 BTC 144, that deeds of allocation did not give rise to deemed disposals for capital gains tax purposes under sec. 25(3) of the Finance Act 1965. (The provisions of that section are now contained in sec. 54(1) of the Capital Gains Tax Act 1979.)

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