Queen’s Bench Division.

Sir Gervase Sheldon.

Judgment delivered 25 November 1988.

Stamp duty – Relief – Reconstruction or amalgamation of company – Undertakings of two subsidiaries were transferred to a third subsidiary in return for issue of new shares – New shares subsequently transferred to holding company for cash – Whether conditions for relief were satisfied – Whether provisional relief granted should be forfeited – Finance Act 1927, sec. 55(1)(c)(i), (6)(a) (repealed by the Finance Act 1986, sec. 74(1) and Sch. 23, Pt. IX).

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