House of Lords.

Judgment delivered 21 July 1988.

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.

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