Court of Appeal (Civil Division).

Beldam, Potter and Chadwick LJJ.

Judgment delivered 29 January 1999.

Corporation tax – Allowable losses – Sale in 1990 of shares in subsidiaries with unrelieved losses by a group of companies to another group – Payment of 50 per cent of tax saved to be paid when losses utilised or, if not utilised within five years, as if utilised at 31 March 1995 – Change in the law in 1993 prevented their use – Whether purchaser obliged to make payment – Finance Act 1993, s. 88; Taxation of Chargeable Gains Act 1992, Sch. 7A.

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