Court of Appeal.

Judgment delivered 24 July 1987.

Corporation tax – Chargeable gains – Capital sum derived from assets – Member of group sold companies to outside purchaser – Group holding company covenanted that no group member would compete with companies sold for five years – Whether consideration for covenant was capital sum derived from assets – Finance Act 1965, sec. 22(3) (now Capital Gains Tax Act 1979, sec. 20(1)).

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