Privy Council.

Lord Bridge of Harwich, Lord Oliver of Aylmerton, Lord Goff of Chieveley, Lord Jauncey of Tullichettle and Lord Lowry.

Judgment delivered 13 November 1990.

Profits tax – Sale of shares – Bank rescue of company in difficulties – New issue of shares in company purchased by bank’s subsidiary – Shares sold after four years for profit – Whether sale of capital asset or trading transaction.

  This was an appeal by the taxpayer from the decision of the Hong Kong Court of Appeal, reversing the decision of the High Court and the Board of Review, that a sale of shares was a trading transaction.

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