Court of Appeal (Civil Division).

[The appeal against this decision is reported at [1993] BTC 8003.]

Nourse and Staughton L JJ and Sir Christopher Slade.

Judgment delivered 19 February 1992.

Capital transfer tax – Settled property – Steps taken to mitigate tax – Whether Ramsay principle applied – Whether any combination of steps to be treated as single composite transaction – If not whether part of settled property reverting to settlor exempt – Finance Act 1975, Sch. 5, para. 4(2)(5) (replaced by the Inheritance Tax Act 1984, sec. 52(1), 53(3)(5)).

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.