Court of Appeal (Civil Division).

Millett and Roch LJJ and Sir John Balcombe.

Judgment delivered 4 December 1997.

Stamp duty – Conveyance on sale – Contract for sale and declaration of trust passed equitable interest in property in the UK – Documents executed in Jersey where they remained – Transfer of legal estate presented for stamping not specifying consideration – Whether transfer a ‘conveyance on sale’ chargeable with ad valorem stamp duty – Stamp Act 1891, s. 14(4), 15(2)(a), 61(2).

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