Court of Appeal.

Slade, Nourse and Butler-Sloss L.JJ.

Judgment delivered 10 March 1989.

Capital duty – Exemption – Allotment of shares – Share exchange by which company acquired at least 75 per cent of share capital of another company – Two allotments included on one return – 75 per cent of issued share capital achieved only by second allotment – Whether ‘transaction’ attracting exemption consisted of both allotments together or whether only second allotment qualified for exemption – Finance Act 1973, sec. 47, Sch. 19, para. 10; Council Directive 69/335/EEC, Art. 7(1)(bb).

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