Craven (H.M. Inspector of Taxes) v White; Inland Revenue Commissioners v Bowater Property Developments Ltd.; Baylis (H.M. Inspector of Taxes) v Gregory. 1988 BTC 268
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.