Court of Appeal.

[The appeal against this decision is reported at [1988] BTC 268.]

Judgment delivered 24 March 1987.

Capital gains tax – Tax avoidance – Scope of Ramsay principle – Taxpayers intended to dispose of shares in family business – Shares exchanged for shares in offshore company to defer capital gains tax – Proposed sale not proceeded with – Sale renegotiated with same purchaser – Whether Ramsay principle applied to treat taxpayers as having disposed of shares direct to purchaser.