Court of Appeal.

[The appeal against this decision is reported at [1988] BTC 8065.]

Judgment delivered 18 December 1986.

Capital transfer tax – Settlement held on discretionary trusts – Capital distribution – Arrangement reduced value of settled property – Beneficiary became entitled to interest in possession – Whether arrangement formed part of series of associated operations – Finance Act 1975, sec. 20(4), Sch. 5, para. 6(3).

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