Court of Appeal.

Judgment delivered 21 October 1983.

Income tax – Artificial transactions in land – Grant of lease to developer – Premium for lease related to payments received for underleases – Whether tax avoidance provisions apply – Whether gain obtained from the disposal of land – Whether an arrangement or scheme – Income and Corporation Taxes Act 1970, sec. 488(1), (2).

  This was an appeal by the taxpayer against a decision of Warner J. in the Chancery Division, to the effect that income tax rather than capital gains tax was payable in respect of premiums received from developed land.

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