DR J F AVERY JONES CBE; MR T H K EVERETT

Decision released 10 May 1999

Inheritance tax - Tax avoidance - Associated operations - Settlement of shares followed by purchase of own shares - Whether associated operation and so business relief not available

HEADNOTE

The issue was whether business relief from inheritance tax was precluded by reason of ‘associated operations’ or by the Ramsay principle.

The four appellants who were brothers, each held 25 per cent of the issued share capital of Computers Ltd. In 1995 Megacomputers negotiated terms for the purchase of Computers Ltd and the brothers took advice as to the most tax efficient course to take.

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