Chancery Division.

[The appeal against this decision is reported at [1999] BTC 267.]

Evans-Lombe J.

Judgment delivered 19 November 1997.

Income tax – Transfer of assets abroad by individuals ordinarily resident in the UK – Settlement named the taxpayer and his wife as ‘excluded persons’ – Settlement also gave power to trustees to transfer trust property to another settlement which would cease to be regarded as held on the terms of the first settlement – Whether taxpayer had ‘power to enjoy’ property – Income and Corporation Taxes Act 1970, s. 478(1); Income and Corporation Taxes Act 1988, s. 739(2).

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