House of Lords.

Lord Keith of Kinkel, Lord Templeman, Lord Ackner, Lord Browne-Wilkinson and Lord Mustill.

Judgment delivered 1 July 1993.

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, sec. 47(1A), Sch. 5, para. 1(6), 4(2), (4), (5) (replaced by Inheritance Tax Act 1984, sec. 144, 44(1), 52(1), 53(3), (5) respectively).

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