Chancery Division.

[The appeal against this decision is reported at [1998] BTC 8003.]

Lindsay J.

Judgment delivered 23 May 1996.

Stamp duty – Conveyance on sale – Agreement and declaration of trust relating to sale of property in the UK executed and retained in Jersey – Transfer of property submitted for stamping – Whether transfer a conveyance on sale chargeable with ad valorem stamp duty – Whether declaration of trust could be accepted as evidence – Stamp Act 1891, s. 14(4), 15(2)(a).

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