Court of Appeal.

Judgment delivered 18 May 1983.

Capital transfer tax – Appointment of property held on protective trusts – Construction of legislative provision – Retrospective application of charging provision – Finance Act 1975, Sch. 5, para. 15, 18Finance Act 1978, sec. 71.

  This was an appeal by taxpayer/trustees from the decision of Nourse J., reported at 82 BTC 8023, that Finance Act 1978, sec. 71, applied retrospectively to charge to capital transfer tax an appointment of trust property made before the passing of that Act.

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