Chancery Division.

[The appeal against this decision is reported at [1987] BTC 226.]

Judgment delivered 26 November 1985.

Capital gains tax – Disposal – Tax avoidance scheme – Composite transaction – Pre-ordained series of transactions – Sale of shares in exchange for shares in Isle of Man company to avoid tax – Sale of shares by Isle of Man company two years later – Whether disposal by original shareholders to ultimate purchaser – Finance Act 1965, Sch. 7, para. 4 and 6(2) (now Capital Gains Tax Act 1979, sec. 78 and 85).

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