Chancery Division.

Vinelott J.

Judgment delivered 23, 26 June 1989.

Corporation tax – Losses – Shares in company which had become of little value transferred by parent to subsidiary – Shares in subsidiary sold to another group in two stages within three days – Loss on shares crystallised at first stage – Between the two stages worthless shares sold to another subsidiary – Two-stage sale adopted for both fiscal and commercial purposes – Whether Ramsay principle applied to treat the first stage as a nullity – Income and Corporation Taxes Act 1970, sec. 278, Capital Gains Tax Act 1979, sec. 62.

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