Privy Council.

Judgment delivered 20 October 1986.

Privy Council – New Zealand income tax – Group of companies – Agreement to sell issued share capital of subsidiary company to another group of companies – Taxpayer companies purchasing tax benefit of loss sustained by another company – Sole purpose of sale to gain tax benefit – Whether loss of one group member deductible from assessable income of another – Income Tax Act (New Zealand) 1976, sec. 99, 191.

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