Chancery Division.

Vinelott J.

Judgment delivered 22 June 1992.

Capital transfer tax – Interest in possession in settled property – Close company’s interest in possession in settled property attributed to participators – Disposal of interest in possession to be treated as termination of interest – Taxpayer transferred shares in close company to trustees of charity – Whether transfer of value – Whether exemption for gifts to charity applied – Finance Act 1975, Sch. 5, para. 4(1), (2), 24(5); Sch. 6, para. 10(1), 15(3)(ba) (replaced by the Inheritance Tax Act 1984, sec. 51(1), 52(1), 101(1), 23(1), 56(3) respectively).

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