Court of Appeal (Civil Division).

Dame Elizabeth Butler-Sloss P, Robert Walker and May LJJ.

Judgment delivered 24 February 2000.

Income tax – Exemption – Approved pension schemes – Sub-underwriting of share issues – Whether sub-underwriting was taxable under Sch. D, Case I as a trade and not under Sch. D, Case VI – Whether exemption applied – Income and Corporation Taxes Act 1988, s. 592(3).

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