Chancery Division.

[The appeal against this decision is reported at [1993] BTC 355.]

Millett J.

Judgment delivered 5 December 1991.

Corporation tax – Chargeable gain – Group of companies – Transfer of shares in subsidiary within the group in exchange for issue of shares in transferee – Sale of transferred shares outside the group – Whether base value of shares in computing chargeable gain to be their value when acquired by the group or their value when transferred from one group member to another – Whether share exchange a ‘disposal’ – Income and Corporation Taxes Act 1970, sec. 273(1); Capital Gains Tax Act 1979, sec. 78.

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