Court of Appeal (Civil Division).

Glidewell, Hobhouse and Morritt L JJ.

Judgment delivered 16 December 1994.

Income tax – Tax avoidance – Transfer of assets abroad – Private portfolio bonds – Whether transferor must be ordinarily resident in UK at time of transfer to be caught by anti-avoidance provision – Whether offshore premium bonds attracted relief provided for offshore capital redemption policies where taxpayer controlled investments – Income and Corporation Taxes Act 1988, s. 553, 739(1), 741.

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