Guinness plc v Inland Revenue Commissioners.  BTC 8003
Judgment delivered 10 December 1993.
Capital duty – Exemption – Allotment of shares – Share exchange by which company acquired at least 75 per cent of share capital of another company for shares in acquiring company and cash amounting to more than ten per cent of total consideration – Block allotments split between shares acquired for shares and shares acquired for cash – Whether allotments for shares attracted exemption – Finance Act 1973, s. 47, Sch. 19, para. 10(2)(b) (capital duty was abolished by the Finance Act 1988, s. 141).